Nov. 8, 2018 —
Dr. Jill Jermano is a senior executive at the U.S. Department of Treasury, an adjunct faculty member at the National Intelligence University, and a professorial lecturer at the George Washington University. The opinions and conclusions expressed in this product are solely those of the author and do not necessarily represent the views of the U.S. Department of the Treasury, the Department of Defense, or any other federal agency.
Coercive U.S. strategies often feature the use of economic and financial sanctions to address national security threats. According to the most recent U.S. National Security Strategy, sanctions and other economic tools “. . . can be important parts of broader strategies to deter, coerce, and constrain adversaries.”1 Sanctions’ potency derives from U.S. economic power, and they generally involve lower cost and risk than the use of military force.
The U.S. Government (USG) has increased the use of economic and financial sanctions against other states and non-state actors in the post–Cold War era, refining their design to improve precision.2 Achieving desired effects with sanctions, however, requires careful assessment of target vulnerabilities, available U.S. leverage, orchestration with other policy tools, and potential obstacles and risks.3
The Nature and Effects of Economic and Financial Sanctions
The use of sanctions in coercive strategies to effect behavioral change involves the sender demanding that the target cease or reverse an action, backing the demand by a credible threat. Sanctions aim to change a target’s decision calculus about resisting pressure by increasing the cost and difficulty of the target’s economic activity or financial transactions. Targeted trade sanctions, for example, can make imported consumer goods and industrial inputs more expensive and difficult to obtain, boosting inflation and dampening productivity and possibly economic growth if substitutes are unavailable. Sanctioning exports can deprive a target country of revenue, increase unemployment in export sectors, and erode domestic firms’ competitive advantage in overseas markets.
Financial sanctions rely on cooperation from banks and other financial institutions to restrict or deny a target’s ability to obtain financial services or capital. Freezing elites’ overseas assets or blocking their transactions can prevent them from accessing their wealth or doing business. Sanctions banning foreign investment in key economic sectors or curtailing access to capital markets and hard currency can threaten targeted firms’ liquidity, decrease productivity, and erode economic growth. Reinforcing these effects are the prohibitions sanctions impose on U.S. persons from conducting business or financial activity with sanctioned individuals or entities.5 Sanctions can also affect foreign entities that do business with a target. Private sector entities often opt to cut ties to avoid jeopardizing their reputation and market share and incurring penalties and fines. U.S. sanctions against key Iranian banks beginning in 2006, followed by European Union (EU) sanctions and financial restrictions in a number of UN Security Council Resolutions led numerous global banks and other multinational firms to stop doing business with Iran, significantly diminishing its ability to trade and attract foreign investment.6 Some firms, however, may view sanctions as an opportunity to profit from the target’s situation and expand or capture market share, particularly when risks seem manageable. A recent example from the Iran case was the banking official from a major Turkish bank who was convicted in a U.S. Federal District Court in January 2018 for helping Iran violate U.S. sanctions.7
Table 1 lists the many measures applicable primarily to foreign governments, associated elites, and national economic sectors, but strategies against non-state actors also make use of targeted sanctions. For example, U.S. counternarcotics efforts since the 1990s have included sanctions against drug cartels and kingpins.8 After 9/11, the United States and foreign governments expanded use of targeted sanctions against terrorists and other illicit actors and their support networks.9 Asset freezes and blocking actions can disrupt the ability of these groups to access the financial system and deter persons and entities from facilitating their operations.
Sanctions Evaluation and Selection
Decisions to include sanctions—or any other policy instrument—in a coercive strategy should reflect an assessment of the target’s vulnerabilities. Vulnerabilities are different for states and non-state actors (see Table 2), but they generally reflect economic or financial dependencies, chokepoints, and exposure that a sender can exploit to affect the target’s costs, risks, and ability to continue the objectionable conduct. State vulnerabilities can derive from a country’s economic conditions as well as its reliance on foreign economic relationships and market and financial access.10 Following Russian interference in Ukraine in 2014, the United States and the EU imposed financial sanctions on political elites close to President Putin and sectoral sanctions on state-owned energy, defense, and financial entities that relied on access to Western capital, foreign investment, and technology.11
Non-state actors’ vulnerabilities can stem from the nature and locations of their economic or financial activities, funding sources, and reliance on third-party facilitators.12 Early post–9/11 U.S. counterterrorism sanctions, for example, targeted individuals and entities that provided material support to al-Qaeda.13 U.S. and multilateral efforts to target the Islamic State of Iraq and the Levant (ISIL) in recent years have focused on denying the group access to funds and assets located in territory it has controlled.14
Not all vulnerabilities present an opportunity to apply pressure. In the era of targeted sanctions, U.S. decisionmakers generally avoid certain types of economic coercion, such as trade sanctions limiting a target’s imports of food staples or medicine that ultimately could harm civilians.15
A vulnerability assessment helps to determine if sanctions are an option, but it is also important to evaluate U.S. leverage over a target. Leverage is the ability to exploit vulnerabilities stemming from the target’s ties to or reliance on the sender or entities under sender jurisdiction.16 U.S. leverage derives from the size of the U.S. economy and the U.S. dollar’s central role in global trade and capital markets and enables the USG to wield considerable influence, but actual U.S. leverage is context dependent.17 Situations involving limited U.S. leverage may require coordinating sanctions actions with governments better-positioned to pressure a target, if they have a shared interest in doing so. For example, Russia’s extensive economic ties with Europe have given the EU more leverage than the United States for coercing Moscow.18 Unilateral U.S. sanctions, including measures aimed at a target’s external supporters, might be a better option if multilateral support is limited or when the United States has more leverage over third parties than the target.19
When existing leverage appears sufficient to exploit target vulnerabilities with sanctions, the process of imposing sanctions requires determining whether existing U.S. sanctions authorities provide the basis for taking action. U.S. sanctions derive from statute and presidential executive orders. Congress can include sanctions provisions in legislation to address national security and foreign policy issues. The President may issue an executive order for the purpose of implementing such a law, meeting U.S. obligations under UN sanctions, or initiating new sanctions based on his emergency powers.20 The U.S. Department of the Treasury (DOT) in coordination with the Departments of State (DOS) and Justice (DOJ), and other federal agencies implement and enforce sanctions pursuant to executive orders and statute.
The process of imposing sanctions involves preparing a legal case for the action and coordinating with interagency actors to identify and de-conflict equities and competing priorities and assess legal sufficiency.21 Interagency coordination of a strategy featuring sanctions also involves weighing options for timing and sequencing the use of sanctions with other policy instruments and assessing relevant domestic and international factors, political constraints, and national and global economic conditions. As with any policy tool, competing domestic policy priorities and U.S. bureaucratic obstacles can affect political will to implement and sustain sanctions over time.
Meghan O’Sullivan, Harvard University professor and former Deputy National Security Advisor for Iraq and Afghanistan during the George W. Bush Administration, argues that coherent and effective strategies combine sanctions with other policy instruments to augment the impact of the action on the target.22 For example, informational tools such as a public announcement in the form of a Federal Register notice and a press release are usually part of a sanctions action.23 Publicizing sanctions sends a message to multiple audiences, including the target and its constituents, other governments, private sector entities that could be affected by the action or that do business with the target, and the U.S. public.
Sanctions actions also often have a diplomatic dimension, such as engaging the target directly or indirectly before or after imposing sanctions to send a warning or sustain pressure during negotiations.24 U.S. and multilateral sanctions on Iran remained in place during several years of P5+1—China, France, Russia, the United Kingdom, and the United States plus Germany—negotiations with Tehran that led to the 2015 deal on Iran’s nuclear program.25 U.S. consultation with allies and partners helps coordinate the timing of a multilateral sanctions action, and diplomatic outreach to governments and foreign firms can alert them to the action or the issues at stake, enlist their support, or warn them of the consequences of undermining the sanctions.26 Direct USG engagement with foreign private sector entities to warn them of the risks of doing business with Iran was key to the effective isolation of Iran from the global economy.27
Sanctions can also coincide with U.S. or multilateral law enforcement actions, such as seizing or forfeiting a target’s assets in addition to freezing or blocking them.28 One example was DOJ’s announcement in 2014 of the seizure of more than $6 million in funds associated with sanctioned front companies for Li Fang Wei, a Chinese national the USG had sanctioned in 2009, who was charged in U.S. Federal Court with operating a network to procure controlled goods for Iran.29 Law enforcement measures can augment the effects of sanctions on the target and potentially deter third parties from helping the target evade the measures.
Sanction actions may also precede or occur concurrently with the threat or use of military force. Imposing sanctions prior to kinetic action is one way to increase pressure to persuade the target that ceding would be less costly in the near term. For example, U.S. and multilateral sanctions against the Federal Republic of Yugoslavia occurred prior to and continued after NATO airstrikes against Bosnian Serb targets began in August 1995, ultimately serving as a bargaining chip in the Dayton Peace negotiations.30 The simultaneous use of sanctions and military action can amplify the overall impact on the target. Multilateral efforts to counter the financing of terrorism, for example, have combined targeted sanctions with the use of force.31
As with any strategy to achieve national security goals, it is necessary to assess the soundness of a coercion attempt involving sanctions prior to taking action, even if sanctions are designed to play a minor role relative to other tools. Sanctions sometimes can have unanticipated effects, be challenging to implement, and produce unintended consequences for U.S. interests, allies, and partners.
One factor to consider is the expected impact of the measures on the target—what kind of damage will it suffer, and how will it and other parties react? Sanctions can have negative unintended effects on the target, neighboring jurisdictions, or third parties; the use of targeted sanctions has reduced but not eliminated this possibility.32 Sanctions can also undermine other U.S. foreign policy goals and potentially damage U.S. relations with countries with a stake in the issue.
Another risk is the target’s ability to evade, work around, or mitigate the impact of sanctions by using its own resources or relying on external facilitators. For example, the former Iraqi regime in the late 1990s extensively circumvented sanctions to generate revenue and buy the loyalty of the military and security services.33 The Iraq case is an example of how sanctions busting can contribute to what Andreas calls the “criminalization” of a target regime and the broader economy and society, as government officials partner with illicit actors to work around sanctions.34 In recent years, expert panels established to monitor compliance with UN sanctions regimes have extensively documented evasion techniques targeted states have adopted in response to escalating U.S. and international pressure.35 The March 2018 report of the UN Panel of Experts established for the North Korea sanctions regime, for example, describes the North’s “increasingly sophisticated evasion practices,” including the use of illicit shipping techniques to circumvent the UN’s export ban on specific North Korean commodities and Pyongyang’s use of complicit third-party nationals and service providers to facilitate financial and trade transactions.36 The DOT and the U.S. Coast Guard jointly published an advisory this February that detailed the North’s deceptive shipping practices, such as changing vessel identifiers, disabling and manipulating automatic identification systems, falsifying shipping documentation, and using ship-to-ship transfers of sanctioned cargo.37
The Venezuelan regime’s establishment in early 2017 of the “petro,” a national cryptocurrency allegedly backed by Venezuelan oil reserves, for the stated purpose of evading U.S. sanctions that have isolated the country from accessing U.S. debt markets represents a new innovation for Caracas and other states seeking to mitigate the effects of coercive U.S. economic pressure.38 In the near term, the petro is unlikely to shield Venezuela from U.S. sanctions as long as foreign investors are reluctant to invest in a rapidly deteriorating economy beset by hyperinflation.39 The USG responded to Venezuela’s move by prohibiting U.S. individuals and firms from all dealings in any Venezuelan digital currency, coin, or token, which could further deter non-U.S. investors with U.S. exposure.40 Sovereign cryptocurrencies will provide Venezuela, Russia, and other oil exporters only limited relief from U.S. sanctions as long as the U.S. dollar remains the primary currency of the global oil trade.41 On the horizon, however, the increasing integration of crypto-assets in international financial markets could provide new opportunities for sanctions evasion or mitigation.42
Retaliatory measures by the target or an outside supporter is another risk. For example, Miller argues U.S. efforts to freeze Japan’s U.S.-based assets in 1941 were a catalyst for Tokyo’s decision to attack Pearl Harbor.43 Moscow responded to Western sanctions in 2014 by banning agricultural imports from the United States and the EU, which was the largest source of food exports to Russia at the time.44 The action sharply reduced Russia’s imports of EU agricultural products while boosting Russian domestic food production, but EU producers were able to shift some exports to other markets.45 Non-state actors typically have less ability to respond in kind to U.S. actions, but can resort to asymmetric methods. For example, Hezbollah in June 2016 may have bombed a Beirut bank in reaction to Lebanese banks’ compliance with the U.S. Hizbollah International Financing Prevention Act.46
The USG’s use of sanctions depends on private sector cooperation, so the impact of sanctions on industry is another potential risk. U.S. and foreign financial firms in particular have incurred increasing costs to ensure compliance with sanctions.47 The impact on firms’ bottom lines means that sanctions actions can meet resistance from the domestic business community and interest groups. Two major U.S. business lobbying organizations in June 2014 publicly warned U.S. sanctions on Russia would negatively affect U.S. manufacturing and jobs.48
Before imposing sanctions, it is worth revisiting initial assessments of expected impact, risks, feasibility, costs, and implications. The process of establishing a baseline expectation of the outcome can inform an assessment of the actual use of sanctions in the context of the overall strategy.
Evaluating the outcome of a sanctions action involves measuring impact and effectiveness. Impact is the actual effect of the sanctions on the target as well as the target’s response and third-party reactions. It can be challenging to gauge impact, especially if reliable data are limited, target decisionmaking is unclear, or other political or economic variables are at play. Effectiveness is the extent to which sanctions achieve policy goals.49 The literature’s tendency to conflate impact and effectiveness reflects a long-running debate about whether sanctions “work.”50 Skeptics who highlight instances of targets refusing to compromise or cede to senders’ demands often examine the use of sanctions in isolation from other instruments, which does not reflect actual practice. This perspective also tends to rely on empirical cases involving broad trade restrictions rather than the targeted sanctions that became more common in the 1990s and 2000s.51 For example, U.S. sanctions imposed on North Korea in the 1950s included an embargo on U.S. exports and denial of Most-Favored Nation trade status, whereas the George W. Bush Administration used new post–9/11 targeted authorities to curtail North Korea’s access to the U.S. financial system.52
A strategy’s effectiveness in achieving policy goals rests on the coordinated use of multiple tools of statecraft. The comparative utility of sanctions reflects their contribution to the outcome of a strategy relative to that of the other tools.53 Measuring effectiveness and comparative utility can be difficult if there are multiple objectives or if the combined use of several instruments produces synergies or multiplier effects.
The attractiveness of economic and financial sanctions reflects their potential to augment coercive strategies for achieving foreign policy goals, but their successful use depends on careful evaluation of target vulnerabilities and available U.S. leverage to exploit them, orchestration dynamics, expected impact, and factors that could affect implementation. These types of assessments inform both strategy design and outcome and help decisionmakers determine if course corrections are needed. Target adaptation to sanctions might help identify new nodes to pressure and disrupt as well as sanctions loopholes to close. Efforts by other states or actors to facilitate sanctions evasion may point to the benefit of secondary sanctions. Unintended consequences for domestic firms or innocent populations may require allowing exemptions. Or target resilience to economic pressure may underscore the need to adjust the strategy to emphasize use of another tool of statecraft. PRISM
1 President Donald Trump, National Security Strategy of the United States of America, (Washington, DC: The White House, 2017), 34, available at <https://www.whitehouse.gov/wp-content/uploads/2017/12/NSS-Final-12-18-2017-0905.pdf>.
2 Robert D. Blackwill and Jennifer M. Harris, War by Other Means: Geoeconomics and Statecraft (Cambridge, MA: The Belknap Press of Harvard University Press, 2016), 197.
3 This article follows the literature’s convention of referring to the country or multilateral organization imposing sanctions as the “sender” and the party subject to sanctions as the “target.” For example, see Jonathan Kirshner, “The Microfoundations of Economic Sanctions,” Security Studies 6, no. 3 (Spring 1997): 33, available at <https://www.tandfonline.com/doi/abs/10.1080/09636419708429314?journalCode=fsst20>.
4 Sue E. Eckert, Thomas J. Biersteker, and Marcos Tourinho, “Introduction,” in Targeted Sanctions: The Impacts and Effectiveness of United Nations Action, ed. Sue E. Eckert, Thomas J. Biersteker, and Marcos Tourinho (Cambridge, UK: Cambridge University Press, 2016), 1–3.
5 U.S. persons include U.S. citizens, permanent resident aliens, U.S. companies and their foreign branches, and foreign nationals and companies present or based in the United States. R. Richard Newcomb, “Targeted Financial Sanctions: The U.S. Model,” in Smart Sanctions: Targeting Economic Statecraft, eds. David Cortright and George A. Lopez (Lanham, MD: Roman & Littlefield Publishers, Inc., 2002), 45.
6 Rachael L. Loeffler, “Bank Shots: How the Financial System Can Isolate Rogues,” Foreign Affairs 88, no. 2 (March/April 2009), 105–08, available at <https://www.foreignaffairs.com/articles/north-korea/2009-03-01/bank-shots>.
7 Benjamin Weiserjan and Carlotta Gall, “Banker from Turkey is Convicted in U.S. Over Plot to Evade Iran Sanctions,” The New York Times, January 3, 2018, available at <https://www.nytimes.com/2018/01/03/world/europe/turkey-iran-sanctions-trial.html>.
8 See U.S. Department of the Treasury, Narcotics Sanctions Program, July 18, 2014, available at <https://www.treasury.gov/resourcecenter/sanctions/Programs/Documents/drugs.pdf>.
9 Zarate details U.S. and multilateral efforts after 9/11 to use sanctions and other targeted financial measures against terrorist organizations and other illicit actors. Juan C. Zarate, Treasury’s War: The Unleashing of a New Era of Financial Warfare (New York, NY: Public Affairs, 2013), chapters 1–4. United Nations Security Council Resolution 2253 (2015), available at <https://www.un.org/en/ga/search/view_doc.asp?symbol=S/RES/2253(2015)>.
10 Newcomb, 49–50.
11 William E. Pomeranz, “Sanctions Finally Find Russia’s Achilles Heel,” Reuters, July 23, 2014, available at <http://blogs.reuters.com/great-debate/2014/07/23/sanctions-finally-find-russias-achilles-heel/>; Marcus Walker, Matthew Dalton, and Carol E. Lee, “Europe, U.S. Significantly Expand Sanctions Against Russian Economy,” The Wall Street Journal, July 29, 2014, available at <https://www.wsj.com/articles/europe-u-s-significantly-expand-sanctions-against-
russian-economy-1406666111>; Peter Baker and Andrew Higgins, “U.S. and European Sanctions Take Aim at Putin’s Economic Efforts,” The New York Times, September 12, 2014, available at <https://www.nytimes.com/2014/09/13/world/europe/european-union-details-tightened-sanctions-against-russia.html>.
12 For example, see U.S. Congress, House of Representatives, Committee on Foreign Affairs, Testimony of Matthew Levitt, “Attacking Hezbollah’s Financial Network: Policy Options,” 115th Cong., 1st sess., June 8, 2017, available at <http://www.washingtoninstitute.org/policy-analysis/view/attacking-hezbollahs-financial-network-policy-options>; Jacob N. Shapiro and David A. Siegel, “Underfunding in Terrorist Organizations,” International Studies Quarterly 51, no. 2 (June 2007), 426–27, available at <http://cisac.fsi.stanford.edu/sites/default/files/Shapiro_Underfunding_in_Terrorist_Organizations.pdf>.
13 Zarate, 37–38.
14 United Nations Security Council Resolution 2253 (2015), available at <https://www.un.org/en/ga/search/view_doc.asp?symbol=S/RES/2253(2015)>.
15 Newcomb, 47–48.
16 On the balancing of political leverage for effective use of sanctions, see Elizabeth Rosenberg et al., The New Tools of Economic Warfare (Washington, DC: Center for a New American Security [CNAS], April 15, 2016), 39, available at <https://s3.amazonaws.com/files.cnas.org/documents/CNASReport-EconomicWarfare-160408v02.pdf>.
17 Blackwill and Harris, 3.
18 Edward Fishman, “Even Smarter Sanctions: How to Fight in the Era of Economic Warfare,” Foreign Affairs 96, no. 6 (2017), 104, available at <https://www.foreignaffairs.com/articles/2017-10-16/even-smarter-sanctions>.
19 The United States can impose “secondary” (or extraterritorial) sanctions against non-U.S. third parties to compel or deter them from doing business with a designated target. See Meredith Rathbone, Peter Jeydel, and Amy Lentz, “Sanctions, Sanctions Everywhere: Forging a Path,” Georgetown Journal of International Law 44, no 3 (2013): 1070, available at <https://www.law.georgetown.edu/academics/law-journals/gjil/recent/upload/zsx00313001055.PDF>.
20 The International Emergency Economic Powers Act enables the President to declare a national emergency related to a national security threat and impose sanctions by designating specific individuals or entities. The President can also issue an executive order pursuant to the UN Participation Act to implement a UN Security Council Resolution. Designated individuals and entities appear on the Treasury Department’s Specially Designated Nationals and Blocked Persons (SDN) list, which is available at <https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx>.
21 See Newcomb, 48–49, 52–55.
22 Meghan L. O’Sullivan, Shrewd Sanctions: Statecraft and State Sponsors of Terrorism (Washington, DC: Brookings Institution Press, 2003), 288.
23 Newcomb, 55–56. The Federal Register is the U.S. Government’s official journal, available at <https://www.federalregister.gov/>.
24 See O’Sullivan, 288, on combining sanctions with dialogue with the target.
25 Arms Control Association, Fact Sheet: Timeline of Nuclear Diplomacy with Iran, May 2018, available at <https://www.armscontrol.org/factsheet/Timeline-of-Nuclear-Diplomacy-With-Iran>.
26 See Newcomb, 56.
27 Loeffler, 106.
28 See United States General Accountability Office, Financial Institutions: Fines, Penalties, and Forfeitures for Violations of Financial Crimes and Sanctions Requirements, GAO-16-297 (Washington, DC: GAO, March 2016), available at <http://www.gao.gov/assets/680/675987.pdf>.
29 U.S. Department of Justice, “‘Karl Lee’ Charged in Manhattan Federal Court with Using a Web of Front Companies to Evade Sanctions,” April 29, 2014, available at <https://www.fbi.gov/contact-us/field-offices/newyork/news/press-releases/karl-lee-charged-in-manhattan-federal-court-with-using-a-web-of-front-companies-to-evade-u.s.-sanctions>. U.S. Department of the Treasury, Press Release, “Treasury Targets Networks for Facilitating Iran’s Ballistic Missile Procurement and Supporting Oil Sanctions Evasion,” April 29, 2014, available at <https://www.treasury.gov/press-center/press-releases/Pages/jl2372.aspx>.
30 David Cortright and George A. Lopez, The Sanctions Decade: Assessing UN Strategies in the 1990s (Boulder, CO: Lynne Rienner Publishers, Inc., 2000), 79–80; Gary Clyde Hufbauer, Jeffrey J. Scott, Kimberly Ann Elliott, and Barbara Oegg, Economic Sanctions Reconsidered, 3rd Edition (Washington, DC: Peterson Institute for International Economics, 2009), 175–76.
31 For example, see Joby Warrick, “Coalition Efforts Are Putting ISIS in the Red,” The Washington Post, January 1, 2017, A01, available at <https://www.pressreader.com/usa/the-washington-post-sunday/20170101/281500750921785>.
32 Rosenthal et. al., 19; Bruce W. Jentleson, “Economic Sanctions and Post-Cold War Conflicts: Challenges for Theory and Policy,” in ed. Paul C. Stern ad Daniel Druckman, International Conflict Resolution After the Cold War (Washington, DC: National Academies Press, 2000), 146, available at <https://www.nap.edu/read/9897/chapter/5#128>.
33 O’Sullivan, 131–32.
34 Peter Andreas, “Criminalizing Consequences of Sanctions: Embargo Busting and Its Legacy,” International Studies Quarterly 49, no. 2 (June 2005), 335, available at <https://onlinelibrary.wiley.com/doi/abs/10.1111/j.0020-8833.2005.00347.x>.
35 An overview of UN sanctions regimes and the committees and panels that monitor their implementation and compliance is available at <https://www.un.org/sc/suborg/en/sanctions/information>.
36 UN Security Council, Report of the Panel of Experts Established Pursuant to Resolution 1874 (2009), S/2018/171, March 5, 2018, 4–5, available at <http://www.un.org/ga/search/view_doc.asp?symbol=S/2018/171>.
37 U.S. Department of the Treasury, “Sanctions Risks Related to North Korea’s Shipping Practices,” February 23, 2018, available at <https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Documents/dprk_vessel_advisory_02232018.pdf>.
38 Kejal Vyas, “U.S. Bans Use of Venezuela’s Cryptocurrency,” The Wall Street Journal, March 19, 2018, available at <https://www.wsj.com/articles/u-s-
39 “Venezuela’s “crypto-currency”: A Sunny Place for a Shady Currency,” The Economist, March 17, 2018, 36–7, available at <https://www.economist.com/news/americas/21738948-petro-probably-scam-better-
40 Executive Order 13827 of March 19, 2018, “Taking Additional Steps to Address the Situation in Venezuela,” Federal Register Vol. 83, No. 55, available at <https://www.treasury.gov/resource-center/sanctions/Programs/Documents/13827.pdf>.
41 David Tweed, “Bitcoin Can’t Save the World’s Autocrats from the Sanctions Squeeze,” Bloomberg, January 15, 2018, available at <https://www.bloomberg.com/news/articles/2018-01-15/bitcoin-can-t-save-world-s-autocrats-from-the-sanctions-squeeze>.
42 Nathaniel Popper, Oleg Matsnev, and Ana Vanessa Herrero, “To Evade Sting of U.S. Sanctions, Nations Ponder Digital Currency,” The New York Times, January 3, 2018, available at <https://www.nytimes.com/2018/01/03/technology/russia-venezuela-virtual-currencies.html>.
43 Edward S. Miller, Bankrupting the Enemy: The U.S. Financial Siege of Japan Before Pearl Harbor (Annapolis, MD: Naval Institute Press, 2007), 1–2.
44 Polina Devitt and Maria Tsvetkova, “Russia Bans all U.S. Food, EU Fruit and Veg in Sanctions Response; NATO Fears Invasion,” Reuters, August 6, 2014, available at <https://www.reuters.com/article/us-ukraine-crisis/russia-bans-all-u-s-food-eu-fruit-and-vegetables-in-sanctions-response-nato-fears-invasion-idUSKBN0G61K220140806>; European Parliament Directorate-General for External Policies Policy Department, Russia’s and the EU’s Sanctions: Economic and Trade Effects, Compliance and the Way Forward, October 2017, EP/EXPO/B/INTA/2017/11, October 2017, 16, available at http://www.europarl.europa.eu/RegData/etudes/STUD/2017/603847/EXPO_STU(2017)603847_EN.pdf.
45 European Parliament Directorate-General for External Policies Policy Department, 17–18, 25.
46 Josh Wood, “Hizbollah Sanctions Back Lebanon’s Banks into a Corner,” The National, July 12, 2016, available at <https://www.thenational.ae/world/hizbollah-sanctions-back-lebanon-s-banks-into-a-corner-1.165976>
47 Meurant Luc“Financial Crime Compliance: The Case for an Industrywide Approach,” American Banker, August 18, 2014, available at <https://www.americanbanker.com/opinion/financial-crime-compliance-the-case-for-an-industrywide-approach>.
48 Kenneth Rapoza, “U.S. Exports to Russia Rise Despite Tensions, Minor Sanctions,” Forbes, July 4, 2014, available at https://www.forbes.com/sites/kenrapoza/2014/07/04/u-s-exports-to-russia-rise-despite-tensions-minor-sanctions/#642b95fa63bb
49 See O’Sullivan, 27–28.
50 For example, see Robert A. Pape, “Why Economic Sanctions Do Not Work,” International Security 22, no. 2 (Fall 1997), 90–136, available <https://web.stanford.edu/class/ips216/Readings/pape_97%20(jstor).pdf>; Robert A. Pape, “Why Economic Sanctions Still Do Not Work,” International Security 23, no 1 (Summer 1998): 66–77, available at <https://www.mitpressjournals.org/doi/abs/10.1162/isec.23.1.66>; and Kimberly Ann Elliott, “The Sanctions Glass: Half Full or Completely Empty?” International Security 23, no. 1 (Summer 1998): 50–65, available at <https://www.mitpressjournals.org/doi/abs/10.1162/isec.23.1.50>.
51 Jentleson, 141.
52 Dianne E. Rennack, North Korea: Economic Sanctions, RL31696 (Washington D.C.: Congressional Research Service, 2003), 9–10, available at <https://fas.org/sgp/crs/row/RL31696.pdf>; Zarate, 225.
53 O’Sullivan, 29, distinguishes comparative utility from utility—the ability of sanctions to achieve policy goals at reasonable or proportionate cost.
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