The Elements of Sanctions Ripe for Reform

Economic statecraft, and sanctions in particular, are popular policy instruments because they promise to deliver leverage at someone else’s expense. Sanctions can create pressure by taking away something of value to an adversary and then promising to return it if that adversary changes its policy or behavior. Economic statecraft takes this concept further into a broader package of economic incentives and disincentives that, at its most effective, can result in political and diplomatic wins while also creating economic opportunity for the country utilizing it.

Sanctions have not always proved effective in practice. Successful examples do exist: international sanctions against South African apartheid in the 1990s and Iran’s nuclear program in the 2010s are the clearest, though not without controversy. Failures are easier to point to, such as those intended to persuade North Korea to dismantle its nuclear arsenal in the early 2000s, convince Venezuela’s leadership to abide by the terms of elections and respect civil rights in the first Trump and Biden administrations, and support political reforms in Zimbabwe throughout the 2000s. A good number of “incompletes”—for which the outcome isn’t yet certain—also exist, such as the use of sanctions by multiple countries against Russia after its unprovoked invasion of Ukraine in 2022.

Reform is necessary to make these tools more consistently effective and efficient. This series of blog posts examines four possible aspects of reform: doctrine, organization, legislation, and outreach. The focus is primarily on the United States, both because it is one of the countries most practiced at economic statecraft and because the author is most familiar with its work. But universal lessons can be drawn from the US experience for other nations seeking to improve sanctions outcomes.

Similarly, this blog series discusses sanctions in general. The energy sector has been at the core of many US sanctions throughout history, often focusing on oil trade, financial investment, or technology transfer to enhance energy production. As a major element of a country’s economy and basic ability to operate, energy-related sanctions make sense to strategists looking to apply pressure and pain to advance their foreign policy. But reforms to address their functioning would apply across all such efforts, and the sections that follow therefore take a wide tack to cover all possible target areas.

Doctrine

Sanctions policy would be more effective, structured, and explainable if encapsulated in a doctrine—an overall conceptual underpinning or approach. Defining a sanctions doctrine early in every presidential administration in the United States (and, as appropriate, in other governments and multilateral organizations like the EU) could lend form and structure to what otherwise can be an unwieldy mess of actions and reactions. Identifying a common, cohesive approach for the employment of national power helps a government understand what it is supposed to do and steer its constituent parts to the same objective. Doctrine also helps to identify what is not part of the desired approach, avoiding waste and confusion.

Missing Piece

For all the talk about sanctions being a crucial tool of foreign policy, it is difficult to spot a prevailing doctrine for sanctions use. This is somewhat surprising, given that many other facets of foreign policy have such a device. Military force has often been the subject of strategic doctrine: In the 1950s and 1960s, concepts such as “massive retaliation” or “flexible response” for the US use of nuclear weapons in response to Soviet aggression were the subject of presidential campaigns. Development, too, has been governed by doctrines, such as whether it is better to localize support or centrally manage it. Diplomats may be less fixated on doctrine than soldiers but often follow a set of ideas or notions about how they can be successful in their engagements. Yet sanctions are rarely discussed in the form of doctrine.

Some nascent efforts to establish a framework akin to a doctrine in the United States include the 2021 Treasury Sanctions Reform project, which had elements of doctrine such as setting a requirement to establish objectives for sanctions, assess of their impact, and bring in partners to participate. But it still set the point of departure that when sanctions are used, they ought to be used in a sensible manner. Some scholars have advanced the notion of sanctions doctrine in the European Union, but there doesn’t appear in publicly available sources to be such a doctrine or framework either in use or in development in the EU. If other countries have a guiding sanctions doctrine—other than to follow the decisions of the United Nations Security Council—it is not apparent.

Even where the bones of a doctrine are in place, adherence to it has been ephemeral. For example, during the 1990s and 2000s, elements of doctrine began to emerge, emphasizing that only “smart sanctions” would be employed. Just as with smart bombs, the theory was that sanctions could be designed to minimize their unintended consequences and ensure all of their destructive power was felt by their target. However, this was conceptually less a “doctrine” than a limitation on the use of force: the equivalent of a stated desire to avoid killing civilians in war rather than a structured approach to how a war should be fought and won, and a limitation that gradually diminished.

Defining Doctrine

Constituent parts of a sanction’s doctrine would be different for air warfare or foreign assistance, for example, but some elements are needed in any definition of doctrine. These include the following, best expressed as questions:

Objectives: Why are sanctions being employed?
Resourcing: Are sanctions the primary, secondary, or tertiary tool? Defining their value as a tool and how they figure in the decision-making paradigms of leaders is crucial to understanding how much emphasis they should be given in policy making and who should lead their implementation.
Appropriateness: Which sanctions measure (e.g., travel ban, asset freeze, export ban) is most effective to apply?
International participation: Is international participation an objective in its own right—for example, as a means of conferring legitimacy on sanctions in a particular circumstance or ensuring efficacy—or a matter more of convenience or symbolism?
Risk tolerance: How much consideration should be given to the domestic economic or political risks of sanctions? Are concerns over domestic economic interests more or less important than the efficacy as sanctions as a tool?
Humanitarian implications: How much do humanitarian issues matter?
Incrementalism or maximum pressure: Would this issue benefit from applying all possible sanctions quickly or would longer term, more patient approaches be more effective?

To this last point on pressure, in 1984 and 1991, US officials outlined the concept of decisive military action as the baseline approach to any military involvement. At its heart, this doctrine espoused immediate use of the most decisive means possible to address a problem and rejected the idea of limited force usage. In sanctions terms, this approach would involve using as much sanctions pressure as is expected for ultimate success as quickly as possible, rather than ratcheting up pressure over time. Naturally, there are limitations to how effective sanctions can be in a short time period—even asset freezes, which can impose a considerable amount of pain very quickly, do not necessarily manifest their most significant effects overnight. As an alternative construct to the usual sanctions practice of methodically adding pressure over time, however, it bears consideration.

As the prior questions suggest, the focus in setting doctrine should be on helping identify the main parameters and goals for action. To be useful, sanctions doctrine has to apply broadly, making it clear which measures are off the table and which are not. It also must set broad terms of reference in order to be of value. Doctrine is of little use if it makes all situations “context dependent.”

Certainly, some variability must be allowed in any sanctions case. North Korea and Iran are very different countries, for example, with distinct histories, cultures, economic conditions, and international relationships. They merit being handled on an individual basis. But it is still possible to develop a doctrine for a government that applies to both. For example, a doctrine might state that: In cases involving nuclear proliferation, we will prioritize multilateral participation in the development of sanctions and ensure that sanctions are focused on individuals and entities involved in the nuclear program rather than on the broader economy. Such a statement automatically identifies areas of sanctions consideration that are in bounds and out of bounds. It also conveys a sense of prioritization of effort and constituent elements.

The same government could also have doctrine that deals with other problems and identifies what would be in bounds or out of bounds. For example, building on the previous doctrinal line, one could add: In cases involving human rights violations, we will hold individuals responsible and deny them access to the United States, while working with the government involved to address our concerns. In cases involving support for Russia in its war with Ukraine, we will use sanctions to end Russia’s ability to acquire components for its weapon systems, including by denying a country and its companies access to the US economy, working with partners where useful.

This language now contains a wealth of information to support a differentiated approach to sanctions while at the same time giving real guidance across the field of sanctions. Of course, defining a doctrine and specifying priorities creates political risk for governments and sanctions officials because some issues are raised up the ladder of importance and others down. Governments are often reluctant to do that since it can create uncomfortable dynamics around prioritization internally and problems with public messaging externally. Governments should be aware, though, that this differentiation is obvious in the number of targets sanctioned and associated diplomatic work, even if it is not stated outright.

Organization

If “personnel is policy,” then organization is implementation of policy. In the interface between decisions being made and being carried out is a world of opportunity for interpretation, misunderstanding, or confusion. Organization, lines of authority, and consultative mechanisms all feed into an implementation process and, in many ways, can determine the success or failure of the enterprise.

Every government has a different approach to the organization of sanctions and economic statecraft policy. Cultural, historical, and constitutional factors underlie many of the organizational approaches countries take, but improvements and reforms are possible in every system.

Organizing Elements

Sanctions work best when they have clear objectives, are informed by cogent and accurate analysis of the sanctions target, and can be modified as time and circumstances change. This points to a few elements for organizing around sanctions.

First, sanctions policy decisions need to be integrated into the broader policy decision matrix, and the leadership of their implementation needs to be part of those decision-making circles. In turn, sanctions officials should be expected to outline how they will achieve results and the potential risks and costs of their actions.

Second, strong information gathering and analytical resources are needed. All sanctions programs are dependent on information and, in places where the rules allow it, support from intelligence agencies is crucial. But classified information is not always allowed in sanctions cases, so other ways of conducting analysis or gathering data are needed. For example, conducting relational analyses of how companies or common business partners are linked, incorporating investigative journalist reporting, and using datasets such as those identifying beneficial owners can all contribute to making sanctions cases stick without resorting to cloak-and-dagger tactics.

Third, sanctions are most effective when there is a plan. Sanctions have evolved into crisis response tools and few if any governments spend time or resources in long-range sanctions planning. Sanctions campaigns could be gamed out well in advance of a crisis, with plans serving to identify targets, information gaps, and vulnerability to countermeasures, even if the plans need to be updated later based on continencies.

Organizational Reform

Given the elements of organizing success discussed above, the United States could consider the following three actions as part of a sanctions reform package:

Create a Joint Staff

The United States could create a structure for sanctions similar to the military’s joint staff, the purpose of which would be to conduct long-term assessments of economic, political, and technical trends that would affect the economic statecraft of the United States and to plan for scenarios that could require the use of US economic power in response. The military’s joint staff has 2,000 employees; however, a smaller organization could be created for economic statecraft that could meet similar needs, particularly if it were authorized to engage with industry and private sector actors to utilize their expertise in analysis and operational planning. It would be able to do the research and thinking into sanctions concepts that current sanctions investigators cannot do without taking away from their day jobs, which are focused on establishing the facts of misdeeds that allow sanctions to be imposed. It would also provide some analytical distance from those directed to make sanctions work to opine on the utility of courses of action once developed.

Such an organization could also help ensure that resource allocation for sanctions targets is in line with their value proposition. In the author’s experience, resources tend to be prioritized to the hottest target, even if the value proposition of sanctioning that particular entity may be less. And every sanctions action against a target requires the same workload for sanctions investigators. A joint staff configuration could provide assessments as to the relative value proposition of targets under consideration and help to ensure that prioritization across the many sanctions programs in the United States is in keeping with the costs borne through the investigations and imposition of sanctions.

Consolidate in a Single Office

A sanctions joint staff could be housed in a number of plausible places, highlighting the abundance of sanctions-focused organizations within the US government.

Currently, arms-related sanctions are housed at both the Departments of State and Commerce, and responsibility for embargo enforcement is split between Commerce and Treasury. A business representative visiting Washington to discuss sanctions issues would need to schedule appointments in at least three buildings, and that’s before considering the White House or Congress. This system was not planned, it grew out of structures that made sense during and following World War II. But there are ways to streamline and consolidate efforts. Efficient policy coordination can address the challenge of needing multiple offices and agencies to be part of sanctions decisions, given the multiplicity of interests in a sanctions measure (for example, one that targets oil exports).

Bureaucratic politics will push for consolidation at one department or another, but sanctions work could instead be separated into its own agency, responsible to the senior political leadership of the executive branch directly rather than run through a particular department. One could envision a sanctions office similar to the US Trade Representative, responsible for sanctions execution and coordination, at which decisions are made with the agreement of the secretaries of State, Treasury, and Commerce. The director of that office could report to the National Security Advisor, allowing the director to seek senior political support if there were debates between agencies (as is the case in much of the current US government structure). Agencies would be required to support the decisions once reached, but before that stage could debate topics from their perches within the foreign policy system unencumbered by a need to simultaneously weigh the policy value of a decision and the bureaucratic value of garnering credit for action.

The office could also work with the Director of National Intelligence to prioritize support for sanctions-related intelligence information and consolidate sanctions-related analysis functions of the State and Treasury Departments and those of the CIA. Absent that, construction of a sanctions-supporting intelligence center, like those for counterterrorism or counterintelligence, could be pursued.

The office could also be staffed with a variety of experts, from government civil servants to lawyers to private sector professionals or fellows who could lend practical guidance on specific subjects like energy, finance, or transport to make sanctions more efficient.

Share Analyses with Congress

Congress has a keen interest in sanctions development and enforcement, and would be concerned if sanctions policy was consolidated in the executive office of the president, where—in theory—executive privilege could interfere with oversight. This is a real concern, even if oversight could be provided via the implementation of sanctions decisions and the roles of the cabinet secretaries in the process. But it raises the question of the utility and form of current oversight, which, in the author’s experience, is served by occasional briefings, reports, and committee hearings that offer few opportunities for substantive engagement.

Instead of the current system, the executive and legislative branches could construct an approach that allows for more serious, sustained engagement on sanctions cases. This could include the sharing of analysis concerning sanctions implications, target selection, and the relationship between targets and broader US interests. Congressional staff could likewise receive analysis that outlines the nature of available targeting information and how it fits within sanctions enforcement rules, allowing them to understand better how a one-off press story might not capture the wealth of other information available. The executive branch would face new risk from such transparency, as it is currently given discretion by Congress to act in many of these cases; allowing for legislative staffers to probe individual cases on a regular basis could create friction. That said, this can happen already on the basis of assumed knowledge rather than actual facts. If armed with actionable information to support sanctions claims, members of Congress may opt to support existing sanctions tools rather than cut their budgets and add unfunded mandates.

Legislation

Sanctions are a highly legislated topic in the United States because they provide an avenue for lawmakers to be directly involved in foreign policy. In the 2024 National Defense Authorization Act, for example, there are more references to sanctions than “infantry” or “artillery.”

However, Congress largely ceded control over a significant part of the US sanctions apparatus through the International Emergency Economic Powers Act (IEEPA) of 1977. With it, Congress gave the executive branch near total authority to impose sanctions on foreign individuals, entities, and governments, provided the president declare that a national emergency exists and then report to Congress on it regularly. Through IEEPA, presidents have frozen assets, blocked imports and exports, and exerted considerable power over the international economy. There are limits on this power, mainly dealing with humanitarian donations and the international postal service, but the limitations are themselves bounded.

The contrast between IEEPA and other pieces of sanctions legislation is stark, in that IEEPA grants maximum flexibility and other legislation is exceptionally prescriptive, which has an impact on how sanctions are utilized in practice. It also suggests that legislation reform would be a useful element of broader sanctions reform in the United States.

Flexibility’s Price

Somewhat ironically, IEEPA was passed in order to rein in the president’s use of sanctions, as part of a broader effort to circumscribe a perceived overuse of presidential declarations of “national emergencies.” As the special committee appointed by Congress to delve into this issue noted, under previous legislation, the United States was in a state of national emergency from 1933–1976.

Though IEEPA was intended to establish guardrails on the president’s authorities, in practice this has not been the case. National emergencies declared under IEEPA have proven just as durable as those under previous legislation. For over 42 years, until 2019, Congress never voted against a presidential national emergency. And its vote against the national emergency proclaimed by President Donald Trump in 2019 regarding the US border with Mexico went nowhere; Trump’s subsequent veto blocked the attempt to cancel the emergency.

Congress has also been inconsistent in how it approaches sanctions topics. While Congress has ceded much control to the president, it has been incredibly specific as to the types of sanctions it wishes to see in place and how it wishes to see them employed. Moreover, in the cases of Iran, Hezbollah, and Russia, there are limitations on the president’s flexibility to terminate sanctions authorities, even when imposed via IEEPA. The resulting sanctions environment is chaotic and complex.

First, it is very difficult for compliance departments of banks and multinational corporations, let alone the average person, to understand what is permitted and what is not in sanctions. The problem gets worse when entities and individuals are sanctioned under multiple authorities and statutes. This overlapping set of authorities carries a cost in terms of the resources needed to investigate and apply sanctions and creates issues when considering whether and how to remove sanctions.

Second, a tangle of agencies and offices now has a role in sanctions policy. To some extent, there is no avoiding bureaucratic lines crossing in sanctions policy, but legislation has augmented the differentiation of duties, with roles for waivers, implementation, and enforcement mixed and matched depending on the topic. Involved departments also have different standards for considering when sanctions should be removed, the basis for that removal, and how to communicate all of these steps to the public and private sectors.

Legislative Reform

A total reboot of US sanctions policy and practice is unlikely, though another post in this series offered some thoughts as to how it could be reorganized. Either in addition to or instead of those concepts, legislative changes could be pursued.

Congressional Review

Congress could consider changing IEEPA to require more effective and action-oriented congressional review. For example, Congress could amend IEEPA to require that every national emergency sanctions issued by the president be reviewed every four years. This would ensure that each national emergency is considered and debated by Congress during a presidential term. An affirmative vote to continue the sanctions could be required from both chambers within 90 days of the review being launched. If an affirmative vote is not taken, the national emergency would be terminated and not permitted to be restarted for at least a year, absent a subsequent national emergency announcement and immediate affirmative vote.

Some national emergencies would doubtless remain in place (e.g., Iran and North Korea) because the substance is sound or the politics of voting them down would be hard to overcome. Still, the process of debating the emergencies would have some value as far as identifying why they are in place and the executive branch’s plan for resolving them.

Budget Analysis

The House of Representatives could adopt a budget rule that every sanctions provision adopted by Congress be accompanied by an analysis by the Congressional Research Service or Congressional Budget Office of the resource implication of the sanctions before being sent to the president for signature. This analysis could be made public to debate whether existing executive branch budgets are sufficient to address the provision.

Formal Menu of Sanctions Options

If Congress is going to continue to supplement IEEPA with other measures, it should consider legislation that would harmonize the menu of existing sanctions options and give consistency to interpretations and terms that govern sanctions policy. Presently, Congress has generally adapted the menu from the Iran-Libya Sanctions Act of 1996 as its default list of options. This list could be formally standardized and include other sanctions elements that have been fashioned since (such as bans on correspondent banking accounts) so that there is one, universal list of potential options for the executive branch to use.

Congress could also encourage use of the best sanction for the target, avoiding one-size-fits-all approaches that currently require asset freezes on individuals without assets or travel bans on those who do not travel. By doing so, a proper, organized menu could reduce the administrative burden of developing sanctions cases for such targets when the only likely material value of their sanctioning would be the symbolism of their listing; for example, one included option could be the public identification of such individuals.

Sunset Provisions

Congress could insist upon standards for sanctions termination and removal. This can start with the rejuvenation of “sunset clauses,” which set conditions or dates for sanctions to be terminated automatically. Moreover, the conditions should not be unattainable, such as those in the sunset provision of the 2010 Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA, section 401). The laundry list of steps in that act to lift sanctions would require many, fundamental changes in Iranian policy (such as ending its nuclear program, support for proxy groups, and development of missile technology [including space launch vehicles]). The implausibility of meeting these requirements moots the value of sanctions as a negotiating tool.

There are currently no set rules for terminating sanctions against individuals and entities, with discretion given to the president in some cases but not in others. Most sanctions tools can be waived by the executive branch, but the standard for doing so is inconsistent. For example, some pieces of legislation require the invocation of “national security interests” while others require “significant national security interests” and others merely “national interest.” Who gets to decide how these words should be weighed as a signifier of congressional intent is uncertain. Congress itself could try to set a standard for termination of sanctions or waiver usage (e.g., upon a presidential determination of verifiable changes in policy or behavior), or it could delegate that to the president to adopt as part of a broader sanctions doctrine (as examined in another blog post in this series).

Outreach

The public must be aware of sanctions for the tools to be effective. After all, while fines or lost financial access can do considerable damage to an individual entity, the real trick in sanctions is to never have to impose them. Instead, sanctions are most effective when they set up rules of behavior that everyone obeys due to the threat of consequences.

Though public engagement is central to the sanctions enterprise, much of the international sanctions landscape is byzantine and inexplicable to those not steeped in compliance literature or expertise. Even materials intended to address public confusion as to what is allowed or not—including frequently asked questions published by the US Treasury Department—are carefully crafted by lawyers to ensure they do not create inadvertent loopholes or ambiguity. Sanctions are legal instruments, after all. But, the abundance of caution and wordsmithing in sanctions policy has unfortunate side effects when it comes to matters of public engagement and direction to the business community.

For sanctions to be more effective and also to reflect the realities of the international business environment, reforms are needed in sanctions policy outreach.

Key Questions

Policymakers should be able to answer two questions directly and succinctly if they are to use sanctions: Why are you doing this, and what do you want? These questions are central to any use of policy tools, but answering them also points to needed decisions on a slew of sanctions-specific points: What is in scope for the sanctions? How long will they last? What, if any, exceptions are there?

To be fair, the author has seen major improvements in the US Treasury Department’s communications over the past few years. For example, one can compare two press releases, issued 10 years apart: the first on November 19, 2014, targeting drug traffickers, and the second on November, 21, 2024, targeting Gazprombank. The differences are considerable, both in terms of the scope of information concerning the bad acts prompting sanctions as well as in the supplemental information about how sanctions operate. The more recent release even ends with links to associated regulations, the process for the removal of sanctions, and guidelines for enforcement. All of this is an improvement on the past model for sanctions imposition.

However, even with more information conveyed, there are still glaring gaps in the transparency of the more recent sanctions. For example, Gazprombank is a significant financial institution with respect to energy payments to Russia. Mindful of this, some general licenses were issued that will allow for a wind down of some transactions and exemptions for others, but nongovernmental analysts were left to their own interpretations as to why the sanctions were being imposed and whether additional exemptions might be forthcoming. The result is ambiguous intentions on the part of the United States and the potential for misconstrued assessments of the situation by outside actors. Ambiguity can be helpful from a policy standpoint, but not when it muddies the signals the sanctioner intends to send or makes it more likely that actors will evade the sanctions either out of malice or ignorance.

Moreover, as noted in a previous entry in this blog series, clarity as to the underlying doctrine of sanctions imposition can be central to their efficacy. The current US sanctions system does not require much by way of public outreach on sanctions concepts. Under the International Emergency Economic Powers Act, the president need only declare a national emergency to set about using sanctions powers. Congress can pass sanctions legislation through a variety of vehicles, but has no requirement to articulate its theory of the sanctions case or how to achieve any stated goals. Public statements often accompany these steps, but they are usually short on detail or explanation, relying instead on quotes that emphasize the vigor of the action taken or the perfidy of the bad actor. European Union and United Nations sanctions sometimes contain more explanation because they are the subject of multilateral negotiation. In all, sanctions can often be imposed with little articulation of means or ends.

Outreach Reform

Three steps would improve outreach around sanctions and the ability of the public, civil society, and business sector to offer views on implementation and efficacy. The specific steps outlined below pertain to the US sanctions system but could be applied more generally by governments and multilateral organizations with sanctions mandates.

Public Consideration

New sanctions concepts would be imposed only after a period of public consideration in all but the most extreme circumstances. Within the executive branch, the Federal Register is the official publication for communicating changes in government rules, regulations, and policy. On a voluntary basis, an administration could choose to publish presidential memoranda that outline significant new sanctions actions and their intended goals and scope.

An administration could also establish a timetable for receipt of comments on the proposal, just as with federal rule-making, and decide whether and how to respond to any comments received. This process need not include reference to specific designation targets, as this could tip off adversaries to their potential designation, and, as mentioned, could be set aside in the event of a truly exigent circumstance.

Both chambers of Congress could adopt a rule that any significant sanctions measure (i.e., beyond those that reauthorize existing tools or fix modest issues of law) be subject to a hearing prior to passage of legislation. Such a hearing could give members an opportunity to understand better the effects of any proposed sanctions as well as to obtain advice—in public—on any appropriate modifications. Congress could also agree to make public any alternative proposals made and comments received to demonstrate transparency in its sanctions decision-making.

Feedback Loops

Feedback loops are needed in the sanctions process from both the business sector and the public. Policy actions can often go awry, especially when involving complex systems like national economies or industries. Sanctions officials have flexibility to adjust most sanctions, and other elements could be amended in the US context either via executive order or legislation.

Currently, the ability of sanctions officials to obtain information concerning implementation hiccups or similar snags is often limited. In the author’s experience, it usually starts with a company and its legal team contacting the government after sanctions have been imposed to identify a major problem in rollout that sanctions officials didn’t anticipate. The sanctioning of Oleg Deripaska in 2018 on a Friday evening, only to see global aluminum markets go haywire before business opened on Monday due to his company’s centrality to that market, demonstrates the overall problem of information gaps for sanctioners. Public comment mechanisms used in advance of sanctions imposition could be adapted to also permit comments after the fact.

Likewise, congressional hearings or investigations by subcommittee or research staff could be built into major sanctions actions to occur after a period of time for implementation. Doubtless, there would be bad faith efforts by illicit actors to influence this process, but that is happening now and often via opaque lobbying channels. Public means of communication and interrogation of sanctions in open hearings could expose salient points while minimizing the risk of corrupt, backroom deals.

A Single, Searchable List

Sanctions lists should be harmonized within jurisdictions to make it easy for enforcement officials, compliance departments, and citizens to understand who is being sanctioned, why, and the terms of those sanctions. Compliance departments of major corporations gather this information, but it would be far more convenient to have a single, common sanctions listing framework that is searchable. The United Nations does this, as does the European Union, and their lists acknowledge differences in how sanctions are applied against the individuals and entities identified.

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