U.S. Sanctions: Overview for the 119th Congress

The Congressional Research Service released a detailed white paper on U.S. sanctions, providing an in-depth look at the complex and multifaceted nature of sanctions imposed by the United States. The paper, written by Liana W. Rosen, international sanctions and financial crimes specialist, highlights the various forms of sanctions, their objectives, and the roles of different branches of government in implementing and enforcing them. From trade embargoes and export controls to travel restrictions and visa bans, sanctions are a crucial tool for the United States to achieve its foreign policy and national security objectives.

Key Takeaways:

  • Economic sanctions represent a constellation of coercive measures imposed for foreign policy or national security reasons, with the goal of bringing about a change in behavior from the target country or entity.
  • Sanctions may aim to uphold international norms, prevent adversaries from achieving certain military-related capabilities, deter other malign actors from engaging in problematic behavior, and increase costs associated with a certain political decision or activity.
  • Restrictive measures can include trade embargoes; export controls; import limitations; tariffs; procurement bans; conditions on or denials of foreign assistance, loans, or investments; blocking of property; prohibitions on transactions; and travel restrictions.
  • Secondary sanctions may be used to impose additional pressure on a sanctions target, seeking to deter third parties from engaging in activities with the primary target and further restrict the primary target's access to third-party resources.
  • The effectiveness of sanctions depends on domestic compliance and enforcement, participation of other countries in the sanctions regime, the extent to which a target is dependent on economic or political ties to the sanctioning country or countries, and the ability of the target to circumvent or adapt to sanctions.
  • U.S. sanctions target various foreign jurisdictions, governments, individuals, and other entities found to be a source of foreign policy or national security threats, including countries that provide support for international terrorism and human rights abuses.
  • The President has broad decision-making authority regarding the imposition of sanctions, with many U.S. sanctions based on statutorily authorized national emergency powers.
  • The role of executive branch agencies, including the Departments of State, the Treasury, and Commerce, is crucial in administering and enforcing sanctions, with each agency playing a unique role in implementing sanctions programs.
  • Congress plays a key role in establishing sanctions policy through legislation, conducting oversight of sanctions effectiveness, and appropriating funds to resource executive agencies involved in sanctions implementation and enforcement.
  • The 118th and 119th Congresses have passed and introduced numerous sanctions-related bills, addressing issues such as international terrorism, human rights abuses, and the behavior of certain countries, including the People's Republic of China and Iran.

Statistics:

  • There are multiple legal authorities that provide the President with the power to impose economic sanctions, including the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act (NEA).
  • The IEEPA provides the President with the authority to declare a national emergency and impose sanctions in response to an "unusual and extraordinary threat" to the national security, foreign policy, or economy of the United States.
  • The NEA requires the President to transmit to Congress and publish in the Federal Register his decision to continue a national emergency beyond the anniversary of its declaration.
  • The Treasury Department maintains 45 program-specific sanctions regulations and a consolidated list of Specially Designated Nationals (SDNs).
  • The Department of Commerce oversees export licensing and implements controls coordinated with partner countries, with certain lists to which restrictive end-user controls apply, such as the Entity List and Denied Persons List.
  • The Department of Justice investigates and prosecutes sanctions violations, with the Department of Homeland Security overseeing immigration controls and customs policy affecting the importation of goods.

Sources:

  • Congressional Research Service. (2025, September 4). U.S. Sanctions: Overview for the 119th Congress. In Focus white paper (No. IF12390).
  • 50 U.S.C. Sec. 1701 et seq. (International Emergency Economic Powers Act).
  • 50 U.S.C. Sec. 1601 et seq. (National Emergencies Act).
  • 22 U.S.C. Sec. Sec. 7201 et seq. (Trade Sanctions Reform and Export Enhancement Act of 2000).
  • CRS Report R45618, The International Emergency Economic Powers Act: Origins, Evolution, and Use.
  • P.L. 118-42, P.L. 118-47, P.L. 118-50, and P.L. 118-83 (appropriations vehicles).
  • P.L. 118-31 and P.L. 118-159 (national defense authorization acts).
  • P.L. 118-62, the Prohibiting Russian Uranium Imports Act.
  • H.R. 23, H.R. 1450, H.R. 1486, H.R. 1503, H.R. 1540, H.R. 1716, H.R. 1800, and H.R. 1998 (stand-alone legislation).