On Friday, March 9, the Atlantic Council’s Global Business and Economics Program, in cooperation with Georgetown University’s Institute of International Economic Law hosted a conference on Sanctions in the Trump Era – One Year In. The event was hosted in the context of the Global Business & Economics Program’s Economic Sanctions Initiative and focused on best practices of using sanctions as a foreign policy tool.

The first panel of the conference consisted of Ambassador Daniel Fried, a distinguished fellow with the Council’s Future Europe Initiative; Brian O’Toole, non-resident senior fellow with the Global Business & Economics Program; Elizabeth Rosenberg, director of the Energy, Security and Economics Program at the Center for New American Security; and David Tessler, deputy director of Policy Planning at the State Department. The panelists addressed best practices, errors, and the future of the sanctions tool for the US. The panel was moderated by Andrew Keller, partner at Hogan Lovells LLP.

The speakers highlighted the development of sanctions policy under the Trump Administration and Ambassador Fried stressed that there is a competent roster of experts at the Treasury Department who carefully design sanctions policy. Ms. Rosenberg pointed out that Congress plays a significant role in determining and approving newly developed sanctions policy. Mr. O’Toole stressed the necessity of increasing the funding of the governmental instruments dealing with and crafting sanctions policy. He also stated that specificity of target is of vital importance in avoiding the issuance of exemptions and thus eliminating confusion within the private sector. He also noted the importance of taking up a more predictive attitude towards sanctions analysis to improve and hone sanctions as a tool of foreign policy.


The second panel included Michael Greenwald, senior vice president at Tiedemann Wealth Management; Richard Sawaya, vice president of the National Foreign Trade Council; Frederick F. Shaheen, chief counsel on Global Trade at the Boeing Company; and Robert Walsh, deputy chief compliance officer at AXA Group and addressed the private sector’s take on the volatility and uncertainty created by ever-changing sanctions policy and their concerns over compliance. Beth Peters, partner at Hogan Lovells LLP moderated this panel. 

The second panel dealt mostly with the ways in which the private sector can navigate an ever-changing sanctions environment. As Frederick Shaheen stated, large firms and corporations can quickly adjust to new sanctions policy, but smaller firms have a harder time with sanctions compliance and dealing with increased volatility and uncertainty. The panelists noted that the current administration can immensely support the private sector with predictions about what lies ahead. In turn, firms of varying sizes can effectively adjust their compliance policies and avoid inefficiencies.

The Hon. Sigal Mandelker, under secretary for Terrorism and Financial Intelligence at the US Department of the Treasury, delivered the closing remarks of the conference. Ms. Mandelker addressed the importance of tackling the source of funding for bad actors taking advantage of the global financial system to prevent illicit activities such as drug trafficking and terrorism. She emphasized the importance of creating targeted, fine-tuned sanctions policy for maximum results and argued that “sanctions alone are not a foreign policy, sanctions are a tool”, a running thread of the conference.

Related Experts: Daniel Fried and Brian O’Toole