Washington, D.C., October 18, 2021 — Today, the Treasury Department released its long-awaited policy review of U.S. sanctions. The review, first announced by Treasury Secretary Janet Yellen in early 2021, is the culmination of a 9-month, multi-agency process involving the Treasury Department, the National Security Council, and other relevant agencies. It is nine pages long.

“Civil society organizations that have been repeatedly victimized by the unintended consequences of sanctions have been eagerly awaiting this long-overdue policy review of U.S. sanctions, hoping for proposals to address the impediments sanctions cause for humanitarian aid, human rights, peacebuilding and atrocity prevention programs,” said Paul Carroll, Director of the Charity & Security Network. “In many ways, we’re still waiting. This review falls far short of a comprehensive look at sanctions and their unintended consequences, offering nothing in the way of specific policies to address the harmful impacts of sanctions.”

The review notes that the use of sanctions by the U.S. has skyrocketed over the past two decades by a stunning 933 percent.

“Despite a massive uptick in the use of sanctions over the past two decades, there is virtually no accountability taken for the negative consequences of that uptick. As for solutions, there is no mention of the role of sanctions in impeding financial access for nonprofit programs, or suggestions for addressing the trend of bank de-risking of nonprofit clients working in sanctioned locations,” Carroll continued. “Instead of an honest assessment of the shortcomings of U.S. sanctions, the review turns a blind eye to those shortcomings in an effort to ensure that sanctions retain their central role in U.S. foreign policy.”

As the review states plainly, a driving focus of the administration’s efforts to mitigate the unintended consequences of sanctions is to “protect key constituencies and help preserve support for U.S. sanctions policy.” Responding to this, Carroll said, “How can we view this as an honest review of sanctions when a stated purpose of the review is to ensure support for sanctions?”

On Monday, October 18, a coalition of 47 humanitarian, peacebuilding, human rights, faith-based, and other civil society organizations sent a letter to the chairs of the National Defense Authorization Act (NDAA) conference committee urging them to retain an amendment offered by Rep. Jesus (Chuy) García (D-IL) and passed by the House that would require the Government Accountability Office (GAO) to report to Congress on the impact of sanctions on civilians, and on their efficacy in achieving their stated goals.

“The review is at best a baby step towards a smarter sanctions policy, but this can’t be all there is,” said Carroll. “The lack of depth in this review underscores the need for a more robust form of accountability for U.S. sanctions and their unintended consequences. Rep. García’s amendment requiring regular impact assessments on sanctions will help deliver that accountability.”

On Tuesday, October 19, at 10am EST, the Senate Committee on Banking, Housing, and Urban Affairs will hold a hearing on the sanctions policy review with Deputy Treasury Secretary Wally Adeyemo as a witness. “Congress needs to dig in on what this review actually means for U.S. sanctions policy moving forward,” said Carroll.


The Charity & Security Network is a resource and advocacy center working to promote and protect the ability of nonprofit organizations to carry out peacebuilding, humanitarian, and human rights missions and to advance national security frameworks that support rather than impede this work. Learn more about the Charity & Security Network’s work at www.CharityAndSecurity.org, and follow us on Twitter: @CharitySecurity.