In 2022, the United States added 2,275 persons (individuals and entities) to the Specially Designated Nationals and Blocked Persons (SDN) list—a significant escalation in the use of sanctions. In comparison, the United States added 743 persons to the SDN list in 2021. Russia’s further invasion of Ukraine, beginning in February 2022, accounted for 1,698 of the 2,275 total additions.
The Treasury Department placed 577 persons on the SDN list in 2022 for non-Russia-related reasons, which is comparable year-on-year and reflects the continued trend of sanctions as a critical tool in U.S. foreign policy. The significant change in the number of designations between 2021 and 2022 is usually due to current events rather than changes in the underlying sanctions policy. For example, the dramatic decrease in the number of sanctions issued under thematic human rights programs in 2022, such as the Global Magnitsky program, can partly be explained by the prioritization of human rights and large set of sanctions issued before the Summit for Democracy in December 2022. Additionally, policymakers increased use of country-specific sanctions programs rather than thematic-specific sanctions to achieve human rights objectives in 2022. Conversely, the increase in the number of global terror sanctions is a result of the U.S. focus on countering Hezbollah, possibly as part of a broader effort to bring Iran back to Joint Comprehensive Plan of Action (JCPOA) compliance.
The United States also added 519 entities to the Entity List in 2022, prohibiting them from receiving U.S.-origin technology and goods. Most Entity List designations fall on Russia and China, reflecting the growing use of export controls as both a sanctioning instrument and a leading policy tool in managing the U.S.-China strategic competition.
- The number of sanctioned persons on the SDN list increased dramatically in 2022, almost entirely due to increased sanctions on Russia.
- The United States placed 2,275 persons on the SDN list in 2022—only 577 of these designations were not related to Russia. In comparison, 743 persons in total were designated in 2021.
- Most of the 519 Entity List designations in 2022 fell on Russia (72 percent) and China (13 percent).
Country-specific sanctions explicitly target countries—including Burma, the Democratic People’s Republic of Korea (DPRK), Iran, and Russia—whereas thematic sanctions focus on issue areas that cut across national boundaries, such as anticorruption, cybercrime, global terror, and illicit drugs. However, policymakers often use country-specific sanctions programs to target thematic concerns as well, such as leveraging the Iran and North Korea sanctions regimes to counter cybercrime that is concentrated in these two countries. In 2022, Russia was the target of the greatest number—by a large margin—of country-specific sanctions.
Most country-specific sanctions in 2022 target Russia due to its invasion of Ukraine. This paper provides a brief overview of the sanctions packages; a more detailed accounting of the sanctions through May 11, 2022, is available in prior CNAS analysis, “Sanctions by the Numbers: Economic Measures against Russia Following Its 2022 Invasion of Ukraine.” Overall, the sanctions in 2022 targeted individual Russian decision-makers and enablers, as well as Russia’s defense, financial, and energy sectors. In 2022, 1,744 of the designations, which account for 1,698 sanctioned persons, were issued for reasons stemming from the invasion. (See the methodology section for definitions of “designation” and “sanctioned person.”) The United States also used export controls to restrict technology exports to Russia, particularly related to its defense capabilities, which are described in the export control section. Where possible, the imposition of these sanctions was done in lockstep with the Group of Seven (G7) and other partners.
Individual sanctions targeted Russian decision-makers including President Vladimir Putin, as well as the prime minister, foreign minister, and defense minister. These designations continued to expand throughout the invasion. In addition, the United States sanctioned all 450 members of the Russian Duma, the members of the Russian Federation Council, and several military leaders and enablers responsible for the war, including the atrocities in Bucha and purported annexation of territories in eastern Ukraine. The United States also targeted Belarusian leadership—including President Aleksandr Lukashenko—for its aid to Russia.
Within roughly one month of the invasion, the United States issued 459 SDN designations targeting oligarchs and entities connected to the Russian defense industrial base. A notable target during this period was Rostec, a previously sanctioned Russian state-owned conglomerate “whose subsidiaries are engaged in a wide range of industries, including automotive, defense, aviation, and metals.”
The United States and its allies hit the Russian financial sector particularly hard with a series of escalating measures that ultimately led to the immobilization of most of the assets that Russia’s Central Bank, Ministry of Finance, and National Wealth Fund held abroad, as well as the full blocking of all major Russian financial institutions. The Office of Foreign Assets Control (OFAC) sanctioned all five of Russia’s largest banks in 2022. This blocking includes Sberbank, a state-owned bank that is deemed systemically important to the Russian economy because it holds approximately a third of the country’s banking assets and is the main creditor of the Russian economy. Before 2022, it had been carved out of sanctions due to its unique role in the Russian financial system.
Finally, in the energy sector the United States again worked with its G7 allies to impose significant costs on Russia while calibrating blow back to ensure adequate supply and pricing stability in global energy markets given Russia’s large role in the sector. By the end of 2022, all G7 members implemented a ban on imports of Russian oil, liquified natural gas, and coal. They also agreed on a price cap on both Russian seaborne crude oil and petroleum products, which were subsequently implemented on December 5, 2022, and February 5, 2023, respectively. The price caps on crude oil and petroleum products restrict Russian vendors who are selling at prices above the price cap from using services, such as shipping and insurance, that are provided almost exclusively by G7 countries. In effect, the price cap forces Russian firms to sell under the price cap or use inferior and costlier domestically sourced services. The objective of the price cap is two-fold: to put pressure on Russia’s energy revenues while also keeping enough energy on global markets to avoid an energy crisis.
Other Country-Based Sanctions
Iran, North Korea, Belarus, and Burma were also significant targets of country-specific sanctions in 2022. For each country, a democracy, human rights, and anticorruption agenda played a primary role in motivating sanctions last year. A nonproliferation of weapons of mass destruction (WMD) agenda still motivates most sanctions on Iran and North Korea—in line with previous years.
Country-specific designations for Iran in 2022 were more than double those in 2021, at 179 designations and 77 designations, respectively. The human rights–motivated sanctions followed the regime’s crackdown on protests after the September 16 death of Mahsa Amini at the hands of the Iranian Morality Police. To a lesser extent, this increase was also a result of deepening Iran-Russia cooperation, such as the sale of Iranian Shahed drones to Russia following its invasion of Ukraine. Similarly to 2021, a majority of sanctions on Iran target illegal oil and petrochemical sales under the stated goal of seeking “a mutual return to compliance with the Joint Comprehensive Plan of Action.” While these sanctions target Iranian nationals, they can be considered to fall under a thematic nonproliferation agenda because they are directly related to WMDs.
Country-specific North Korea designations were also used more in 2022 than in 2021, with 27 and 9 designations, respectively. Like Iran, this is partially explained by human rights–motivated sanctions on the DPRK—10 designations were made for human rights–related reasons. The remainder of the North Korean designations relate to North Korea’s WMD and ballistic missile program.
There were fewer country-specific sanctions designations on Burma in 2022 (25) than in 2021 (76), which is most likely due to the time lag since the February 2021 coup d’état in Burma. Similarly, the disparity in Belarus sanctions most likely reflects the time lag since the August 2020 fraudulent presidential election. These country-specific sanctions designations for 2022 can be considered to fall under a thematic democracy, human rights, and anticorruption agenda.
The complete lack of Non-SDN Chinese Military Industrial Complex (CMIC) designations in 2022 may suggest that President Joe Biden’s administration will not expand the CMIC program, which began as the Communist Chinese Military Companies (CCMC) program under former President Donald Trump’s administration. Alternatively, the high number of Entity List designations against China might indicate a shift to the Entity List as the tool of choice against China. The more recent conversation about outbound investment controls might also play a role, as the U.S. government seeks a variety of ways to address national security concerns associated with certain U.S. investments in China. Further analysis on China-related sanctions is available in “Sanctions by the Numbers: SDN, CMIC, and Entity List Designations on China.”
There was a general continuity in the number of thematic sanctions from 2021 to 2022, with a sustained focus on human rights, global terror, illicit drugs, and cybercrime in 2022.
The decrease in human rights–related sanctions from 2021 to 2022 likely reflects inflated 2021 numbers due to the first Summit for Democracy in December 2021; 78 of the 176 human rights sanctions in 2021 occurred in December during the lead-up to the summit, suggesting that the Biden administration prioritized human rights sanctions around that time. But even without these, human rights sanctions in 2021 outnumbered that category in 2022 by roughly two to one. The decrease likely reflects the reliance on country-specific rather than thematic sanctions authorities in 2022 to further the United States’ democracy, human rights, and anticorruption agenda. For example, nearly one-third of the Iran and North Korea country-specific designations are related to human rights—highlighting the somewhat arbitrary nature of the “country-specific” and “thematic” categories.
As with Russia sanctions, the Biden administration has placed greater emphasis on coordinating human rights sanctions with allies. For example, the September 22 U.S. designations of the Iranian Morality Police were followed by sanctions from Canada, the United Kingdom, and the European Union.
The 194 global terror designations in 2022—more than double the 98 of 2021—are largely due to an increased focus on Hezbollah. OFAC issued many of these designations in relation to “an international oil smuggling network that facilitated oil trades and generated revenue for Hizballah and the Islamic Revolutionary Guard Corps-Qods Force.” This may reflect the Biden administration’s 2022 push to increase economic pressure on Iran to bring the country back to JCPOA compliance.
Previously, most drug-related sanctions fell under the SDN Narcotics Trafficking Kingpin (SDNTK) authority. The Global Illicit Drug Trade executive order of December 15, 2021, has largely superseded that authority. Taken together, the number of designations pursuant to the two authorities were comparable year-on-year.
Roughly 51 percent of the designations for cybercrime in 2022 were related to the Russian state, compared with about 79 percent in 2021. (The remaining 8 in 2021 are related to Russia-based criminal organization REvil, which was responsible for ransomware attacks on the United States.) Other developments in the cyber space include the designation of virtual currency mixers Blender.io (May 6) and Tornado Cash (August 8), and the redesignation of Tornado Cash (November 8). A currency mixer is a service that anonymizes the ownership of virtual currency and these are often used by malign actors. For example, the Lazarus Group, a North Korean hacker outfit, used both Blender.io and Tornado Cash to launder proceeds of virtual currency heists and other cybercrimes. Previously, the United States designated virtual currency exchanges Suex (September 2021) and Chatex (November 2021), as well as darknet market Hydra (April 2022), in an increased focus on using sanctions to target illicit crypto activity. The sanction on Tornado Cash targets decentralized open-source computer code, rather than an individual or entity, and may reflect an expansion in the interpretation of what is “sanctionable.”
Alternative Economic Tools: The Entity List
The Entity List is an export control tool used to restrict or prohibit the export of U.S.-made goods and technology to designated end users. The United States added 68 Chinese entities to the list in 2022, representing 13 percent of the total, compared to the 374 Russian entities added to the list in 2022, representing 72 percent of the total for the year. Several entities from other countries, such as those in Belarus and Singapore, among others, were added to the list for their role in aiding Russia. On March 9, the Commerce Department listed 96 entities in response to Russia’s invasion of Ukraine, including three from Estonia, three from the United Kingdom, two from Malta, two from Spain, and one from Latvia. Each entity was listed for having “been involved in, contributed to, or otherwise supported the Russian security services, military and defense sectors, and military and/or defense research and development efforts.” Listings for Pakistan and the United Arab Emirates in 2022 are primarily for providing for “Pakistan’s unsafeguarded nuclear activities and ballistic missile program.”
As the United States has broadened the scope of policy objectives for which it uses the Entity List, it has also developed novel rules to expand the scope of products that may be added to the Entity List to include certain goods made outside of the United States. The foreign direct product rules (Entity List FDP Rule) allow the United States to apply U.S. controls on items produced entirely outside of the United States if these products are made using U.S. tools or software. In 2022, 287 entities were listed or relisted under the Russia- and Belarus-specific foreign direct product rule. On October 13, 28 Chinese companies already listed on the Entity List were subjected to a newly created foreign direct product rule that targeted the PRC’s advanced chips, artificial intelligence, and supercomputing capabilities. These high designation numbers targeting Chinese and Russian entities indicate that the Biden administration has increasingly used a combination of sanctions, export controls, and Entity List FDP Rule designations to target the military industrial complexes in China and Russia.
The use of sanctions in 2022 demonstrates that they continue to be one of the U.S. government’s foreign policy tools of choice. As a response to the war in Ukraine, the United States greatly expanded previous sanctions against Russia, making it one of the most heavily sanctioned countries in the world. At the same time, the Biden administration continued its commitment to working with U.S. allies, which resulted in the G7 and other countries imposing their own sanctions against Russia. The United States also continued to increase its use of the Entity List as another lever to achieve its policy goals, including by introducing novel rules that have impacts beyond just goods made in the United States.
It is almost certain that sanctions and export controls will continue to play a major role in U.S. foreign policy throughout 2023. This will include maintaining and possibly expanding Russia sanctions and export controls, potentially restricting Russian assets held abroad, and focusing on Russian evasion tactics. There will likely be a continued focus on using sanctions to achieve goals related to human rights and anticorruption, which remain major priorities for the Biden administration. This will likely continue to be done in coordination with allies as much as possible.
The term “person” denotes an individual or entity, excluding aircraft or maritime vessels. (Previous entries in the Sanctions by the Numbers series have included aircraft and maritime vessels under the definition of “entity.”) A sanctioned person can be designated under multiple authorities: in this case, sanctioned persons are counted once when referring to the number of “sanctioned persons,” and they are counted multiple times, in accordance with the number of sanctioning authorities, when referring to the number of “designations.” For sanction types, the total number of relevant designations is added up. For example, Sberbank Europe AG is listed under Russia-related sanctions authorities UKRAINE-EO13662 and RUSSIA-EO14024, so there is one sanctioned person and two Russia-related designations.
The authors would like to acknowledge the CNAS Communications and Publications Teams for their support, design, and editing. The authors would also like to thank John Hughes, Adjunct Senior Fellow of the Energy, Economics, and Security Program at CNAS, and Emily Kilcrease, Senior Fellow and Director of the Energy, Economics, and Security Program at CNAS, for their reviews of various iterations of the report. This report was made possible with general support to the Energy, Economics, and Security Program.
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About the Authors
Michael Frazer was a Research Contractor for the Energy, Economics, and Security Program at CNAS. He began his CNAS career as a Joseph S. Nye, Jr. Intern for the program. Michael obtained a master’s degree in East Asian studies from The Ohio State University. His interests include economics and Japan. His current focus is on the gold standard in Japan during the prewar period. Michael has studied in Japan and worked as an English teacher for Aeon Corporation in Nagano and as an intern at the Sasakawa Peace Foundation USA. He graduated magna cum laude from New York University with a bachelor’s in linguistics in 2014.
Jocelyn Trainer is a Research Assistant for the Energy, Economics, and Security Program at CNAS. She analyzes developments and trends in sanctions policy and evasion tactics, illicit financial crime, and efforts to combat corruption and human rights abuses, focusing on sub-Saharan Africa, particularly the Horn of Africa. She also researches the nexus between climate change, energy, and national security to inform cross-sectional policy. Trainer leads research and writing for the CNAS Sanctions by the Numbers series.
The CNAS Sanctions by the Numbers series offers comprehensive analysis and graphical visualization of major patterns, changes, and developments in U.S. sanctions policy and economic statecraft. Members of the CNAS Energy, Economics, and Security Program collect and analyze data from publicly available government sources, such as the Treasury Department’s Office of Foreign Assets Control and the Department of Commerce’s Bureau of Industry and Security.
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