The United States’ use of sanctions has exploded over the past decade. An analysis by the law firm Gibson Dunn found that President Donald Trump’s administration added nearly 1,000 people, companies, and entities to U.S. sanctions lists during 2017, nearly 30 percent more than the number added during former President Barack Obama’s last year in office. But expanding sanctions is a rare area of bipartisan consensus in Washington: Obama added nearly three times as many people and entities to sanctions list in his last year in office as he had in 2009.
The explosion of U.S. sanctions is evident not only in the raw numbers of people on U.S. sanctions lists—the scope and complexity of sanctions prohibitions is growing as well. In 2014, the United States invented an entirely new category of penalty, the Sectoral Sanctions Identifications (SSI) List, which prohibits certain kinds of financial transactions with a target company while allowing most others, enabling Washington to target large Russian companies where traditional sanctions could have created unacceptable collateral costs for both the United States and Europe. The Treasury Department applied the model to Venezuela in 2017. And Trump’s merger of sanctions and other national security tools, such as his August 9 decision to impose Section 232 national security tariffs on Turkish steel and aluminum in the context of a diplomatic dispute over a detained American pastor, represents another innovation that has had undeniable economic impacts on Ankara. Trump is also reportedly considering sanctioning Chinese officials and companies over China’s internment of ethnic Uighurs and other Muslims, a move that Beijing would view as highly provocative, while National Security Advisor John Bolton this week publicly threatened to sanction the International Criminal Court if it pursues Americans.
The rapid growth in U.S. sanctions, however, is giving rise to an equally rapid rise in costs and unintended impacts. Some of these are economic. For example, Trump’s August 9 tariffs on Turkey spurred a dramatic market selloff that not only affected Ankara but
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