Thu, Sep 19, 2019

Secondary sanctions’ implications and the transatlantic relationship

The term secondary sanctions provokes strong reactions from allies and markets. Due to the power of the US dollar, breadth of the US market, and dominance of the US financial system, even the threat of secondary sanctions prompts many non-US companies to change their behavior to avoid the risk of such sanctions. Although this approach has furthered US policies, it has resulted in transatlantic political divergence and enhanced compliance uncertainty among private sector actors.

Issue Brief by Samantha Sultoon & Justine Walker

China Economic Sanctions
BRexit Sanctions

Wed, Jun 12, 2019

Britain’s sanction post-Brexit

On June 12, the Global Business and Economics Program’s Economic Sanctions Initiative hosted a private roundtable on the implications of Brexit for the United Kingdom’s sanctions policy, featuring Qudsi Rasheed, sanctions envoy for the UK government. He explained in detail the UK’s new institutional set-up for sanctions policy. Mr. Rasheed also discussed UK-US-EU cooperation on […]

Program Impact Story by Atlantic Council

Economic Sanctions Economy & Business

Thu, Jan 31, 2019

New Venezuela sanctions need timely results

One lesson of sanctions policy is that sanctions can work, but rarely on an ambitious timetable.

New Atlanticist by Samantha Sultoon

Economic Sanctions Venezuela

Samantha Sultoon is a senior fellow with the Atlantic Council’s Global Business & Economics Program and the Scowcroft Center for Strategy and Security. Samantha is also an international affairs fellow with the Council on Foreign Relations.

Formerly a sanctions policy expert for the Department of the Treasury’s Office of Foreign Assets Control (OFAC), Samantha played an active role in the agency’s policy work. This included shaping new policies and regulations for both strengthening (Syria) and easing (Burma, Cuba, Sudan) sanctions measures, and developing and implementing new sanctions authorities (Global Magnitsky, Burundi).  Samantha also created and led the implementation of OFAC’s strategy on Brexit- and EU-related sanctions issues, including diplomatic engagement and technical sanctions capacity building with allies and partners. Throughout her tenure at OFAC, Samantha was instrumental in designing the strategy and implementation of the Obama administration’s historic opening toward Cuba, and in the development and implementation of the Trump administration’s recalibration of Cuba policy. As a senior policy advisor, Samantha also represented OFAC domestically and internationally, conducting outreach and engagements with foreign governments and the private sector.

Prior to her work at OFAC, Samantha was an intelligence advisor in the Treasury Department’s Office of Intelligence and Analysis and a risk expert for the World Bank. There, she managed and edited her team’s global risk publications for the World Bank’s Executive Board. Samantha also led crisis management and business continuity training for World Bank offices in the Middle East and North Africa.

Samantha has an MSc with distinction from the School of Oriental and African Studies (SOAS) at the University of London and a BA from the University of Michigan.