January 29, 2026

Sanctions by the Numbers: 2025 Year in Review

Executive Summary

The second Trump administration has continued to employ financial sanctions and entity-based export controls to pursue its foreign policy and national security goals, even as it has also made extensive use of other economic tools, namely tariffs. The administration’s use of financial sanctions and entity-based export controls in 2025 diverged markedly in some ways from the Biden and first Trump administrations, clearly seen in the decrease in economic statecraft targeting Russia and the surge in sanctions targeting Iran and transnational crime. At the same time, trends in the use of other established sanctions programs have persisted across administrations.

This installment of Sanctions by the Numbers examines the United States’ use of financial sanctions and entity-based export controls through the Treasury Department’s Specially Designated Nationals and Blocked Persons (SDN) List and the Commerce Department’s Entity List. The analysis looks at how the second Trump administration used these tools in 2025, while also comparing the 2025 trends to the first Trump administration and the Biden administration. Alongside this report, the Center for a New American Security is publishing data the Energy, Economics, and Security team collected on SDN List designations and Entity List additions issued between 2017 and 2025, covering the first Trump administration, the Biden administration, and the second Trump administration through the end of 2025.

Key Takeaways

  • Trump vs. Biden: The Trump administration added 1,322 persons to the SDN List and 143 persons to the Entity List in 2025. This marks a significant decrease from 2024, in which the Biden administration added 3,135 persons to the SDN List and 523 persons to the Entity List.
  • Russia: The Trump administration designated just 74 Russian persons on the SDN List and did not add any Russian persons to the Entity List in 2025, a dramatic decrease in the volume of economic pressure aimed at Russia—though the existing sanctions regime was kept largely intact, and the administration sanctioned two major Russian energy companies.
  • Iran: As part of a broader effort by the Trump administration to reimpose “maximum pressure” on Iran, the majority of U.S. financial sanctions in 2025 were issued under authorities aimed at countering malign Iranian activities. Most Iran-related designations targeted Iranian evasion networks based outside of Iran.
  • China: Chinese persons accounted for the largest number of SDN List designations (predominantly for their role in Iran sanctions evasion) and Entity List additions last year. This continues a five-year trend of the People’s Republic of China being a primary target of U.S. economic statecraft, despite Washington’s recent efforts to reach a trade deal with Beijing.
  • Nonstate actors: In 2025, a considerable number of the Trump administration’s sanctions targeted nonstate actors, particularly persons engaging in or facilitating drug trafficking and cybercrime. The administration has frequently portrayed transnational crime, and drug trafficking groups in the Western Hemisphere in particular, as among the among the gravest threats to U.S. national security.
  • Continuity in other programs: Trends in the use of other sanctions programs have persisted across administrations. Annual designations under nonproliferation, global terror, and drug trafficking authorities have increased dramatically across both the Biden and second Trump administrations, reflecting that certain national security challenges have received bipartisan attention.

The analysis is based on the authors’ review of U.S. government data on SDN designations and Entity List additions between 2017 and 2025, including press releases and Federal Register Notices that accompany such designations and additions. (See the Methodology section for details.) The data used in this report can be downloaded below.

Introduction

In 2025, a total of 1,764 persons were placed on the Specially Designated Nationals and Blocked Persons (SDN) List, with 442 designated by the Biden administration in its final weeks and the remaining 1,322 persons sanctioned by the Trump administration. 183 persons were added to the Entity List, with 40 added in the last weeks of the Biden administration and the remaining 143 added by the second Trump administration.

SDN List Overview

The second Trump administration used financial sanctions primarily to counter malign Iranian activities, drug trafficking, and transnational crime—in contrast to the Biden administration, which primarily issued SDN listings under Russia-related authorities during its final month in office. Roughly three-quarters of designations levied by the Trump administration in 2025 were issued under sanctions authorities targeting facilitators of malign Iranian activities, including Iranian and a significant number of Chinese persons. About one-quarter were issued under authorities targeting global terror and roughly 18 percent were issued under authorities targeting members and affiliates of transnational criminal organizations—both of which included a substantial number of Mexican persons as part of the Trump administration’s crackdown on drug trafficking.

U.S. financial sanctions are issued under both country-specific programs to target the policies and actions of a particular government and thematic programs to target malign behaviors on a transnational basis (e.g., drug trafficking). Including both country-specific programs and thematic programs, Chinese, Mexican, and Iranian persons combined accounted for roughly 39 percent of all designations by the Trump administration in 2025. Of note, Chinese persons were sanctioned primarily for their engagement in malign activities outside of China (such as supporting Iranian military capabilities) rather than as part of a U.S. effort to influence the actions of the People’s Republic of China (PRC) itself.

Entity List Overview

The Trump administration added 143 entities to the Entity List in 2025. While this total represented a drastic decline from the average of 507 entities that were added annually between 2022 and 2024 as part of the sanctions campaign against Russia, it was higher than the average of 110 entities added annually by the first Trump administration between 2017 and 2019.

Entity List additions by the Trump administration in 2025 overwhelmingly targeted persons supporting China’s military modernization efforts, evading sanctions and export controls on Iran, and proliferating sensitive goods and technologies to Pakistan. The Biden administration added 40 persons to the Entity List in its final month in office, the majority of which were Chinese persons involved in conducting artificial intelligence (AI) research or contributing to China’s semiconductor capabilities.

Russia

Amid the Trump administration’s ongoing efforts to conclude a peace deal in Ukraine, it was much more restrained than the Biden administration in utilizing sanctions and entity-based export controls to target Russia’s war effort.

In 2025 the Trump administration added only 74 Russian persons to the SDN List, primarily for contributing to Russia’s military and military-industrial base through oil production and illicit oil sales and engaging in malign cyber activities. Notably, the administration announced sanctions on two major Russian oil companies, Rosneft and Lukoil, as well as their subsidiaries, in October 2025, citing a “lack of serious commitment by Russia to a peace process to end the war in Ukraine.” The United States did not add any Russian entities to the Entity List in 2025, but did place five entities, based in Turkey, the United Arab Emirates, and India, on the list for violating export controls and sanctions on Russia.

The second Trump administration’s relatively limited sanctions and export controls on Russian persons in 2025 reflected its reluctance to raise tensions with Moscow amid peace negotiations. The Trump administration did, however, threaten to impose tariffs on countries purchasing Russian oil. These “secondary tariffs” were imposed on India, marking the first time tariffs have been used in this manner, though the ongoing and difficult trade talks with India may have been an important factor in the administration’s decision.

The second Trump administration’s approach toward applying economic pressure on Moscow reflects a dramatic shift from the Biden administration’s unprecedented use of financial sanctions and entity-based export controls on persons contributing to Russia’s war effort. Between 2022 and 2024, the Biden administration levied roughly 1,500 sanctions on Russian persons and roughly 1,800 sanctions under Russia-related authorities per year on average and placed an average of 243 Russian entities on the Entity List. As part of a broader effort to crack down on Russian evasion networks and deny Russia access to sensitive technologies, the Biden administration also dramatically expanded the use of Foreign Direct Product Rules (FDPRs), targeting 766 Russian and non-Russian persons with these extraterritorial export controls on Russian and Belarusian military end users. As noted in last year’s Sanctions by the Numbers: 2024 Year in Review, the Biden administration’s efforts to target Russian evasion networks focused heavily on the PRC.

Despite a different approach to applying economic pressure on Moscow, and speculation about whether it would ease sanctions on Russia, the second Trump administration largely kept the Biden-era sanctions and export controls in place. A total of 38 persons designated under Russia-related authorities by the Biden administration were removed from the SDN List during the first year of the second Trump administration, including the American wife of a Russian oligarch closely associated with Vladimir Putin and other persons that were part of Russian sanctions evasion networks. The number of persons designated under Russia-related authorities that were delisted in 2025 is roughly on par with the Biden administration’s annual average.

Iran

In 2025, the Trump administration applied significant economic and military pressure on Iran, reflecting its view of Iran as the Middle East’s “chief destabilizing force,” articulated in the 2025 National Security Strategy. Iran was a predominant focus of U.S. sanctions and entity-based export controls, and the United States notably conducted Operation Midnight Hammer, a military operation targeting Iranian nuclear facilities, to reinforce the “maximum pressure” campaign across domains.

The Trump administration added 155 Iranian persons to the SDN List in 2025. One hundred fourty-two of these persons were designated under Iran-related regimes, primarily targeting persons involved in the proliferation of weapons of mass destruction. Other Iranian persons were sanctioned under the global terror authority for financially supporting Iran’s terrorist proxies through illicit oil sales and money laundering.

A total of 470 non-Iranian persons were sanctioned by the Trump administration in 2025 under Iran-related authorities, bringing the total number of persons sanctioned by the administration for Iran-related reasons to 612. The administration notably targeted Chinese “teapot” oil refineries, which are responsible for an estimated 90 percent of the oil trade between Iran and China, for the first time.

In addition to targeting Iranian persons, the Trump administration sanctioned transnational Iranian evasion networks extensively. SDN List designations targeting malign Iranian activities, on persons of any nationality, surpassed that of any year from 2017 to 2024—including 2018, when the first Trump administration reimposed sanctions previously lifted under the Joint Comprehensive Plan of Action. The second Trump administration issued nearly the same number of designations under Iran-related authorities during its first year as the Biden administration did during its entire four-year term.

While just three Iranian entities were added to the Entity List by the Trump administration in 2025 for their involvement in procurement networks for Iranian military end users, 36 non-Iranian persons were added for supporting Iran’s military capabilities or Iranian proxy groups. This made Iran-related activities the second-largest target of the administration’s use of the Entity List, after the PRC’s military modernization efforts.

The number of Iranian persons added to the Entity list in 2025 is consistent with the average number of Iranian persons added to the Entity List each year during the Biden and first Trump administrations. Reflecting the Biden administration’s focus on degrading Russia’s war effort, virtually every Iranian person it added was placed on the list for producing drones used by Russia in Ukraine or for being a part of evasion networks benefitting both Iranian and Russian end users. In contrast, every Iranian person placed on the Entity List by the first Trump administration was engaged in malign activities and evasion networks that benefited Iran’s military industrial base or were involved in unsafeguarded nuclear activities.

China

While trade tensions dominated economic and diplomatic relations between Washington and Beijing in 2025, Chinese persons remained a significant target of financial sanctions and entity-based export controls. Chinese persons received more SDN List designations and Entity List additions than any other country, driven largely by Chinese persons’ involvement in Iranian evasion networks and escalating technology competition.

In 2025, the Trump administration added 215 Chinese persons to the SDN List, primarily targeting activity supporting Iran’s weapons development, terrorist networks, and broader malign regional influence. Additionally, Trump sanctioned six government officials in Hong Kong under Executive Order 13936, which focuses on persons undermining democratic processes or peace and stability in Hong Kong—the first use of this authority since 2021. This sparked diplomatic backlash from the PRC and highlighted a slight but significant shift in the United States’ willingness to use sanctions to counter antidemocratic PRC influence in Hong Kong.

The second Trump administration added 95 Chinese persons to the Entity List in 2025. Of these, roughly two-thirds were persons involved in researching, producing, or illicitly acquiring goods and technologies in support of the PRC’s military modernization efforts, particularly its hypersonic missile program and capabilities in quantum, AI, semiconductors, and supercomputing. While the second Trump administration’s use of extraterritorial export controls decreased relative to the first Trump and Biden administrations, applying FDPRs to just 14 entities, the United States continued using these restrictions to target entities contributing to the PRC’s technological capabilities.

During its first year, the second Trump administration also took steps to address long-standing concerns about export control evasion, unveiling the “Affiliates Rule” on September 29, 2025. The rule automatically made any entity in which a person on the Entity List holds at least a 50 percent stake subject to the same Entity List restrictions, on par with longstanding financial sanctions rules. The rule was expected to disproportionately impact China, with WireScreen estimating the number of Chinese persons subject to Entity List restrictions could potentially surge from roughly 1,300 to over 20,000. Beijing retaliated with sweeping export controls on rare earth elements. As part of a broader deal reached between President Trump and Chinese Communist Party General Secretary Xi Jinping in October 2025, Washington agreed to suspend the Affiliates Rule and Beijing agreed to suspend its rare earth controls. The Bureau of Industry and Security (BIS) formally delayed the implementation of the rule for a year on November 10, 2025.

While the number of financial sanctions and export controls targeting Chinese persons in 2025 decreased in absolute terms from 2024, Chinese persons remained a relatively frequent target of U.S. coercive economic statecraft, accounting for roughly 16 percent of all SDN List designations and roughly two-thirds of all Entity List additions by the Trump administration in 2025, despite the administration’s ongoing efforts to conclude a trade deal with Beijing.

Nonstate Illicit Activities

The Trump administration’s use of financial sanctions in 2025 reflected its broader emphasis on combatting the movement of drugs into the United States and efforts to shift national security resources toward the Western Hemisphere, as articulated in the 2025 National Security Strategy. The administration did not utilize the Entity List to pursue this counternarcotics agenda, as this tool is primarily used to curb access to sensitive goods and technologies that present national security risks.

Illicit Drugs

The Trump administration sanctioned 151 persons for their involvement in the illicit drug trade, with most of these being Mexican persons affiliated with cartels like the Sinaloa Cartel and Cartel del Noreste, which President Trump designated as foreign terrorist organizations on his first day in office. Guyanese, Costa Rican, and Colombian cartels and affiliates were also targets of drug trafficking–related sanctions amid a crackdown on emerging Latin American cocaine and fentanyl transshipment networks and hubs.

Drug trafficking–related sanctions have been increasing since the Biden administration, rising sharply in 2023 and remaining high through 2025. Persons designated in 2025 for drug trafficking were often sanctioned simultaneously under sanctions authorities targeting facilitators of terrorism, representing a notable difference in how the current administration views the threat of drug trafficking to U.S. national security. The Trump administration also used other economic tools to pursue its counternarcotics agenda, targeting Mexico, Canada, and China with tariffs in an effort officials portrayed as necessary to curb the flow of fentanyl into the United States.

Transnational Criminal Organizations

The administration also sanctioned 226 persons under the transnational criminal organization (TCO) authority in 2025, the most this authority has ever been used in one year. While Mexican drug cartels and Iranian proxy groups were frequent targets of TCO designations, the U.S. government also sanctioned 146 persons affiliated with Southeast Asian criminal networks perpetuating virtual currency and other cyber scams.

Venezuela

Venezuela emerged as a noteworthy target of sanctions targeting transnational crime and drug trafficking networks, in line with the administration’s broader efforts to target the government of former President Nicolás Maduro. The Trump administration accused Caracas of facilitating narcoterrorism financed by “stolen” oil and declared he had designated the Maduro regime as a Foreign Terrorist Organization on December 16, 2025. President Trump also has said that the Venezuelan government “emptied their prisons into the United States” and sponsored human trafficking. The Trump administration placed 26 Venezuelan persons on the SDN List in 2025, including members of Maduro’s family and leaders of Tren de Aragua, a drug cartel that was designated as a Foreign Terrorist Organization in February 2025.

The second Trump administration also used military means to escalate its campaign against Maduro, including striking multiple Venezuelan drug boats in the Pacific and Caribbean, seizing an oil tanker off of Venezuela’s coast, and conducting a land strike on a Venezuelan shipbuilding facility. These escalating military actions culminated in the early January 2026 capture of Maduro and his wife.

Other Notable Developments

Pakistan: The Trump administration placed 19 Pakistani persons on the Entity List in 2025 for contributing to Pakistan’s unsafeguarded nuclear activities and ballistic missile program. Notably, this meant that Pakistan accounted for the second-largest number of Entity List additions last year. Virtually all of the Pakistani entities added to the Entity List by the Biden and first Trump administrations were listed for similar reasons.

West Bank: The Trump administration terminated Executive Order 14115, which authorized sanctions on persons, primarily Israeli settlers, involved in destabilizing activities in the West Bank. This resulted in all persons previously sanctioned under this authority being delisted.

International Criminal Court: The administration sanctioned 15 judges and prosecutors serving on the International Criminal Court (ICC) and three nongovernmental organizations supporting the ICC’s investigative efforts throughout 2025, citing their “transgressions” and “politicized actions” against Israel and the United States. The first Trump administration had previously sanctioned ICC judges under Executive Order 13928, which was terminated by the Biden administration in 2021.

Syria: Following the fall of the Assad regime in late 2024, the Trump administration effectively terminated the Syria sanctions program in June 2025 by revoking six executive orders which formed part of the comprehensive sanctions regime on Syria. Congress followed suit by repealing the Caesar Syria Civilian Protection Act of 2019 as part of the 2026 National Defense Authorization Act, which included secondary sanctions targeting activities with the country. In order to maintain accountability for ousted President Bashar al-Assad and other persons in his former regime, the Trump administration redesignated them under the Promoting Accountability for Assad and Regional Stabilization Sanctions regulations.

Looking Ahead

While tariffs will likely remain central to the Trump administration’s foreign policy, it will continue to use other economic tools, such as sanctions and export controls, to advance its agenda. The administration’s use of economic statecraft will be shaped by two core elements of its foreign policy: a transactional worldview that prioritizes dealmaking and the conviction that the United States should be willing to utilize its military, diplomatic, and economic power to the extent it deems necessary to achieve its policy aims. The administration has demonstrated its willingness to use military force as a substitute for or complement to economic action when it feels such force would more quickly advance its national security and foreign policy goals, as was seen in Iran and Venezuela. Amid escalating tensions in the Western Hemisphere and ongoing political turmoil in Iran, the administration’s use of military force and economic pressure will play a key role in shaping a rapidly changing global order.

In the economic domain, the administration will likely continue to favor tariffs as a tool to leverage the United States’ role in the international economy, but it may exhibit restraint in applying economic pressure against adversaries, such as Russia, when doing so may impede its efforts to reach economic or diplomatic deals. However, the Trump administration’s use of sanctions and export controls to address concerns related to Iran, China, and drug trafficking networks, as well as to target prominent world leaders and nonstate actors and entities, shows that the Trump administration still values these tools to address national security threats and signal its displeasure with the existing global order.

Terminology & Methodology

Terminology

The term “person” throughout this document denotes an individual or entity, excluding aircraft and maritime vessels. (Entries in the Sanctions by the Numbers series prior to 2022 included aircraft and maritime vessels under the definition of “entity.”)

PRC” refers to the Chinese state. The “party” refers to the Chinese Communist Party.

China” means the entire country, inclusive of nongovernment and nonparty actors. When discussing economic activity, the default term is also “China,” to encompass the range of individuals, firms, and government entities that may be involved in economic activity.

The Specially Designated Nationals and Blocked Persons List is maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). An SDN designation represents the United States’ most stringent financial sanction, prohibiting U.S. persons from engaging in any transaction with the designated individual or entity and freezing all U.S.-based assets associated with them.

The Entity List is maintained by the Commerce Department’s Bureau of Industry and Security. It is used to restrict or prohibit the export of U.S. goods and technologies to listed persons.

Foreign Direct Product Rules are extraterritorial export controls that control the trade of foreign-made goods if these goods are made using U.S. software or equipment.

Methodology

All U.S. government designations and delistings were drawn from the following OFAC sanctions authorities: BALKANS, BALKANS-EO14033, BELARUS, BELARUS-EO14038, BPI-RUSSIA-EO14024, BURMA-EO14014, CAATSA-IRAN, CAATSA-RUSSIA, CAR, CMIC-EO13959, CUBA, CYBER2, CYBER3, CYBER4, DPRK, DPRK2, DPRK3, DPRK4, DPRK-NKSPEA, DRCONGO, ELECTION-EO13848, ETHIOPIA-EO14046, FTO, GLOMAG, HK-EO13936, HOSTAGES-EO14078, HRIT-IR, ICC-EO14203, ICCP-EO13928, IFCA, IFSR, ILLICIT-DRUGS-EO14059, IRAN, IRAN-CON-ARMS-EO, IRAN-EO13846, IRAN-EO13871, IRAN-EO13876, IRAN-EO13902, IRAN-HR, IRAN-TRA, IRGC, LEBANON, LIBYA3, MAGNIT, MALI-EO13882, NICARAGUA, NICARAGUA-NHRAA, NPWMD, NS-PLC, PAARSSR-EO13894, PEESA-EO14039, RUSSIA-EO14024, RUSSIA-EO14065, SDGT, SDNTK, SOMALIA, SOUTH SUDAN, SUDAN-EO14098, SYRIA, SYRIA-CAESAR, SYRIA-EO13894, TCO, UHRPA, UKRAINE-EO13660, UKRAINE-EO13661, UKRAINE-EO13662, UKRAINE-EO13685, VENEZUELA, VENEZUELA-EO13850, VENEZUELA-EO13884, WEST-BANK-EO14115, YEMEN, and ZIMBABWE.

All information regarding additional sanctions, export controls, and other economic measures from the Departments of Commerce and State were drawn from public government sources: Federal Register Notices, press releases, and the BIS Entity List. Data on the specific illicit activity associated with SDN and Entity List designations are taken from OFAC press releases and BIS Federal Register Notices.

There is some uncertainty in quantifying SDN designations by policy priority because U.S. government press releases do not always discuss the sanctionable activity that leads to each designation. For instance, in a round of U.S. government sanctions, there may be 100 designations, but only 50 are called out and explained in the press release. In this case, the report records “at least” 50 designations pursuant to the particular policy priority or illicit activity discussed in the press release.

The Center for a New American Security Energy, Economics & Security Program (EES) uses the justifications given by the BIS in the Federal Register Notices to determine the reason why a specific Entity List addition is made. For example, it counts persons as being placed on the Entity List for contributing to China’s military modernization efforts if the BIS explicitly states they are listing the person for (1) providing goods and technologies to Chinese military end users/People’s Liberation Army authorities, or (2) diverting goods and technologies to China that have potential military applications. Some persons are added to the Entity List for more than one reason. They are counted once in the total number of entities added to the list but are included in the count for each specific reason they were listed.

EES uses nationality to determine the country of an individual placed on the SDN List. This, however, may not necessarily reflect the country of residence or country of origin of an individual. For example, EES would categorize a person of Syrian origin who is a Canadian national under “Canada.” To minimize double counting, in cases where an individual has more than one nationality, EES uses information provided by OFAC to make the best possible determination of their primary nationality.

EES uses the physical address to determine how to categorize entities placed on the SDN List. In instances in which the entity has an address in multiple countries, the entity is labeled under each country in which it is located. For example, an entity based in China and Switzerland would be counted as both a Chinese and a Swiss entity.

OFAC occasionally updates how persons are listed on the SDN List. Most updates simply involve changes to a person’s address or name. However, OFAC sometimes modifies the sanctions authority under which a person is listed or adds an address in another country. EES updates the initial listing to reflect these changes and records the date of the adjustment in a separate column of the included spreadsheet. A person whose listing was modified is counted toward the total number of designations in the year they were initially listed, while the country and regime totals for that year reflect their current listing status. For example, the Trump administration updated the listings of several entities initially designated by the Biden administration for drug trafficking to also include terrorism-related authorities. These entities are counted under both drug trafficking and terrorism authorities for the year in which the Biden administration originally listed them.

Subsidiaries are listed separately on the Entity List and are therefore counted as discrete designations. For instance, in 2020, the total number of designations to which a Foreign Direct Product Rule was applied is entirely attributable to Huawei Technologies and its subsidiaries. For SDN designations, subsidiaries may be listed separately or may be captured under OFAC’s 50 percent rule, which automatically applies the SDN restriction to entities in which the blocked person owns 50 percent or more. In the latter case, EES counts only one designation for the listed person and any additional persons captured under the 50 percent rule.

Sanctions designations often overlap with several different sanctioning authorities, including country-specific and thematic sanctions authorities. In the case where a single designation is pursuant to multiple sanctioning authorities, the designation is counted once within the total designation number but attributed to each pursuant sanctioning authority. For example, if the United States designated Entity X located in China pursuant to GLOMAG and HK-EO13936, then that single designation is recorded once for the total designation of U.S. sanctions but contributes to both the GLOMAG and HK-EO13936 designation counts.

Sanctions numbers for Hong Kong and Macau are included within the total China numbers for this report.

Prior to December 2020, persons with addresses in Hong Kong and mainland China were listed twice on the Entity List—once under Hong Kong and once under China. After December 2020, the BIS ceased treating Hong Kong as a distinct location from mainland China, meaning that entities with addresses in both Hong Kong and China were counted only under China. To avoid double counting, EES counts individuals and entities listed under both Hong Kong and mainland China prior to December 2020 as one person in the numbers in this report. However, the data released alongside this report reflects their distinct listings under both Hong Kong and China.

Foreign Direct Product Rule applications for any given year refer to all entities to which an FDPR was applied. It includes both (1) entities that had an FDPR applied at the time of their listing in the specified year, and (2) entities that were initially placed on the Entity List in a previous year but received an FDPR in the specified year.

The FDPR numbers provided in this report reflect only FDPRs applied to entities added to the Entity List since January 2017. There are a few entities listed prior to this date that had an FDPR applied to them retroactively that are not included in the numbers in this report but had been included in numbers provided in the 2024 Year in Review.

Although the Departments of State and Treasury coordinate closely on sanctions policy and implementation and each have their own sanctions authorities, this report did not make a distinction between the two for analytic purposes. Regardless of which agency has the authority, any sanctions that resulted in persons being put on the SDN List were included in this analysis. Any sanction that did not result in placement on the SDN List was not included.

Since the publication of its 2024 Year in Review, EES has identified and corrected a few instances of data missing or being entered incorrectly. As a result, some of the figures published in this report differ slightly from what was published in 2024 but the analytic conclusions are unchanged.

When the report discusses a specific sanctioned individual or entity, it notes if the sanctioned person or entity has made a public statement or response to their designation on one of the sanctions lists. None of the specific individuals or entities in this report made such a statement.

The names, biographical information, addresses, and information identifying affiliations and business relationships included in the accompanying dataset were directly copied from Recent Action Notices published by the Treasury Department’s Office of Foreign Assets Control and by Federal Register Notices from the Commerce Department’s Bureau of Industry and Security.

Authors

  • Eleanor Hume

    Research Assistant, Energy, Economics, and Security Program

    Eleanor Hume is a research assistant for the Energy, Economics, and Security Program at the Center for a New American Security (CNAS). She supports the Center’s work on Americ...

  • Kyle Rutter

    Program Administrator, Energy, Economics & Security Program

    Kyle Rutter is a program administrator for the Energy, Economics, and Security Program at the Center for a New American Security (CNAS). He graduated cum laude from Florida St...

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