Issue BriefSep 19, 2019
Secondary sanctions’ implications and the transatlantic relationship
By Samantha Sultoon & Justine Walker
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.
New AtlanticistJun 24, 2019
Trump sanctions Iran’s Supreme Leader
By Ashish Kumar Sen
The executive order allows US Treasury Secretary Steven Mnuchin to impose sanctions on officials appointed by Iranian Supreme Leader Ali Khamenei and those who provide material support to his office.
Samantha Sultoon is a nonresident senior fellow with the Atlantic Council’s GeoEconomics Center. 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.