The U.S. Capitol Building is seen at sunset in Washington, May 2017
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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

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  • PETER HARRELL is an Adjunct Senior Fellow at the Center for a New American Security and a lawyer who advises on sanctions compliance. He served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions from 2012 to 2014. He wrote this article while serving as a Visiting Fellow at the University of Pennsylvania's Perry World House.
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