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Summary of GAO Report on Economic Sanctions Implementation and Effectiveness

Core Content

This report, GAO-20-145, provides an analysis of the implementation and effectiveness of U.S. economic sanctions. It outlines the roles of key agencies in sanction enforcement, the types of sanctions used, and the factors that contribute to their effectiveness, based on academic studies. The report was commissioned in response to congressional inquiries and is based on a comprehensive review of legal frameworks, agency practices, and scholarly research.

Main Points

U.S. Economic Sanctions Overview

• The United States maintains 20 country-based or country-related sanctions programs as of July 2019.
• Sanctions can target entire economies, specific sectors, or individuals and entities, and are used to counter a range of threats, including terrorism, narcotics trafficking, weapons proliferation, and human rights abuses.
• Sanctions may be unilateral or multilateral, involving cooperation with international bodies such as the United Nations or the European Union.

Implementation Agencies

• Treasury, State, and Commerce are the primary agencies responsible for implementing U.S. economic sanctions, though other agencies such as the Departments of Defense, Energy, and Justice also play roles in specific contexts.
• Treasury (via OFAC) designates entities, blocks assets, and restricts financial transactions. It also issues licenses and enforces sanctions through investigations.
• State (via SPI) coordinates sanctions implementation, develops policies, and provides foreign policy guidance. It also plays a role in removing sanctions to incentivize improved behavior.
• Commerce (via BIS) controls exports and enforces export regulations, including through investigations and legal reviews.

Sanctions Effectiveness

• U.S. agencies assess the impacts of sanctions on their targets, but face challenges in evaluating their effectiveness in achieving broader policy goals.
• Key factors contributing to more effective sanctions, as identified by studies, include:
  • International coordination (e.g., through the United Nations).
  • Existing U.S. relationships with the target country (e.g., trade or military ties).
  • Comprehensive scope and severity of sanctions.
• However, these studies may not fully reflect the complexity of U.S. sanctions, which often include targeted or secondary sanctions.

Challenges in Assessing Effectiveness

• Agencies struggle to isolate the impact of sanctions from other factors affecting the target country.
• Evolving foreign policy goals complicate the assessment of long-term effectiveness.
• While agencies do not conduct independent evaluations of sanctions effectiveness, their assessments are often used in interagency discussions to guide policy decisions.

Key Information

Types of Sanctions

• Comprehensive sanctions: Broad-based trade restrictions targeting an entire country (e.g., Iran, Cuba).
• Targeted sanctions: Focus on specific individuals or entities (e.g., those involved in terrorism or narcotics trafficking).
• Sectoral sanctions: Target specific economic sectors (e.g., energy, defense) of a country.
• Secondary sanctions: Target third-party actors supporting sanctioned regimes or entities.

Sanctions Implementation Process

• The implementation of sanctions is guided by statutes, executive orders, or interagency agreements.
• When statutory authority is delegated to the National Security Council (NSC), the Principals Coordinating Committee determines the roles of agencies in the sanctions program.
• Agencies typically do not conduct independent assessments of sanctions effectiveness, but they contribute to broader interagency discussions.

Academic Research Findings

• 17 peer-reviewed studies were reviewed, all focusing on the effectiveness and economic impact of sanctions.
• These studies suggest that international cooperation and targeted economic dependency enhance the effectiveness of sanctions.
• Comprehensive and severe sanctions tend to have a greater economic impact, though they may also lead to unintended consequences, such as negative effects on human rights and public health.

Conclusion

The report highlights the complex and multi-agency nature of U.S. economic sanctions, emphasizing the need for coordinated efforts and rigorous evaluation to ensure their effectiveness. While the U.S. has a robust framework for implementing sanctions, the challenges in assessing their impact remain significant, particularly in isolating the effects of sanctions from other variables. The academic research provides valuable insights into the conditions under which sanctions are more likely to be effective, but further analysis is needed to fully understand the nuances of U.S. sanctions policy.