March 11, 2021
Global Sanctions Dashboard: February
In the previous edition of the Global Sanctions Dashboard, the GeoEconomics Center examined sanctions data during the Trump administration’s last month in office. During that time, the United States accounted for nearly half of global sanctions by major powers—amounting to a total of 96 designations and zero delistings. Over the past month, the US introduced 28 new listings and one delisting. Since coming into office, the Biden administration has pursued a foreign policy agenda that contrasts sharply from that of its predecessor. Notably, Iran is absent from this month’s analysis as Washington seeks to re-enter negotiations with Tehran. Understanding where such a shift is translating into sanctions policy, as well as uncovering potential areas of multilateral cooperation, will be the main focus of this edition.
Aligning with allies
The series of challenges to both democracy and human rights that have surfaced during President Biden’s first month in office are striking. As of this writing, over 50 people have died in anti-coup protests in Myanmar, 47 pro-democracy demonstrators have been charged under a controversial national security law in Hong Kong, and thousands of people continue to protest the fraudulent 2020 presidential election in Belarus. With the exception of Hong Kong, the US, UK, EU, Canada, and Switzerland have responded to each challenge in broad policy alignment, but it’s unclear how far any parallel escalation can go.
The jailing of Alexei Navalny in the wake of the FSB’s failed assasination attempt has presented perhaps the most immediate foreign policy challenge. European Union member states recently agreed to designate four Russian officials under its new Magnitsky Act—marking its inaugural use against human rights abusers. Seven Russian officials were also sanctioned by the EU under its chemical weapons authority. The United States joined the EU and UK in sanctioning Russia over Navalny, unveiling a well-coordinated sanctions package that also included measures by the Departments of Commerce and State. The coordination on Navalny sanctions signals that the Kremlin will likely face a more united front from both Europe and the United States as the Biden administration settles in.
Following the declassification of a key intelligence report assessing that Crown Prince Mohammed bin Salman (MbS) authorized the killing of Jamal Khashoggi, the US levied two sanctions against one entity and one individual responsible for the 2018 murder. The Saudi Rapid Intervention Force, unofficially known as ‘Tiger Squad,’ was sanctioned by OFAC in addition to Ahmad Hassan Mohammed al Asiri, the former Deputy Head of Saudi Arabia’s General Intelligence Presidency. These sanctions follow the initial 17 that were levied against Saudi officials immediately following the murder in 2018, and aligned US policy closer to the United Kingdom and Canada. The recent military coup in Myanmar has also prompted a strong coordinated sanctions response. The United States recently designated 10 individuals and three entities involved in the coup, in addition to the United Kingdom and Canada designating nine individuals each. As of this writing, the European Union is also preparing to levy sanctions against those responsible.
Persisting pain points
The ongoing genocide in Xinjiang by Chinese authorities, however, has not evoked the same type of coordinated response. The United States continues to remain the sole authority to sanction human rights abusers in China. How the European Union, the United Kingdom, or Canada expand their Magnitsky sanctions to include these individuals and entities remains to be seen. After long debate, the EU has agreed to–but not announced–limited designations on Chinese officials associated with Xinjiang abuses. In Hong Kong, where the CCP has failed in its promise to respect the ‘one country, two systems’ model, the United States again remains the only authority to sanction those responsible for the region’s democratic erosion. Increased coordination on sanctions between members of the Five Eyes intelligence sharing group would signal a successful multilateralization of efforts to confront Chinese aggression. It would also involve a different constellation of actors and selective multilateralization than those cooperating on Russia.
In the Indo-Pacific community, the ‘Quad’ alliance (India, Japan, Australia, and the United States) seeks to extend its collaboration beyond military affairs. The Biden administration recently announced that the US will for the first time ever engage in joint talks at the leaders level, marking the inaugural session of the Quadrilateral Security Dialogue on March 12th, the day of this publishing.
Concerns over the Nord Stream 2 pipeline are reaching a boiling point in the United States Congress, where both parties are concerned about the political influence the Kremlin may gain over Europe and its ability to sideline Ukraine. Before leaving office, the Trump administration designated both the vessel Fortuna and its parent company KVT-RUS pursuant to Section 232 under CAATSA. The foreign ministers of both Poland and Ukraine voiced support of sanctions against the pipeline, expressing concerns over how the “dangerous, divisive project” threatens Europe’s broader interests and security, but they are wading into a US-domestic political row between Congress and the Executive Branch. Nord Stream 2 has come to exemplify both the broad power and ultimate limitations of US unilateral pressure.
On the radar
Due to the recent ratifications of Magnitsky legislation by key allies, Australia has begun considering its own version. A recent report by the Australian Parliament recommended the drafting of a Magnitsky Act that would “align Australia with a global movement seeking to limit opportunities for human rights abusers, corrupt officials and their beneficiaries to enjoy the proceeds of their abuses.” If such legislation is passed, it will undoubtedly strengthen future multilateral sanction campaigns, particularly in the Indo-Pacific where Australian industry and banking sector may reach deeper than its Atlantic partners.
The jailing of Georgian opposition leader Nika Melia in Tbilisi has fueled concerns over the country’s democratic trajectory, as the recent disputed election continues to polarize the governing party and its opposition. Barring a release, the Melia jailing may prompt international sanctions for violating human rights and undermining democratic norms.
Lastly, as the Biden administration continues to play catch-up on a number of foreign policy issues where the Trump administration fell silent, we can expect additional sanctions on the GRU, Russia’s military intelligence agency. The GRU was recently implicated by the U.S. intelligence community for its involvement in both the SolarWinds hacking and the offering of bounties to Taliban militants to kill American soldiers posted overseas. This will build on last year’s EU sanctions responding to the 2015 hack of the German Bundestag.
Methodology
Castellum.AI obtains global sanctions information from primary sources, and then proceeds to standardize and clean the data, extract key information like IDs and addresses from text blobs, and enrich the entries with additional information. Castellum.AI enriches as many as fifteen separate items per entry. This analysis is based on the enriched primary source data that populates our database. The database consists of over 600 watchlists, covering over 200 countries and six different categories (sanctions, export control, law enforcement most wanted, contract debarment, politically exposed persons and elevated risk). Castellum.AI updates their watchlists every five minutes directly from issuing authorities.
Canada, France and Russia do not use unique IDs for their list which creates challenges relating to tracking changes over time. Many lists have individuals with the same name, and Castellum.AI uses various formulas and methods to identify unique entries. In addition to our algorithms, for Canada Castellum.AI can cross reference press releases, which announce name changes, additions and removals. France and Russia, however, do not publish press releases and their sanctions lists lack consistent structure. As a result, when either France or Russia change entries, they are often dropped and returned as a new one, potentially leading to higher add / drop numbers than other lists.
Michael Albanese is a Research Consultant for the Atlantic Council’s GeoEconomics Center and recently graduated from the University of Maryland, where he studied geoeconomics with a specialization in Russian foreign policy.
The Global Sanctions Dashboard provides a global overview of various sanctions regimes and lists. Each month you will find an update on the most recent listings and delistings and insights into the motivations behind them.
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