Although President Biden’s administration warned that it would conduct a lengthy review of sanctions policy, political events forced the President’s hand, with his first sanctions actions occurring only 22 days into his term. Biden’s Treasury hasn’t stopped since, imposing sanctions in 13 different countries, tackling human rights, election interference, narcotics trafficking and more. On his 100th day in office, the Biden administration announced its nominee for the Under Secretary of Terrorism and Financial Intelligence, a key position at the Department of the Treasury that directs America’s policies on sanctions and financial crime. Based on these hundred days, it will be a busy period for the sanctions world, with the US increasingly working together with allies to impose sanctions, and priorities shifting away from increasing pressure on Iran and Venezuela and towards combatting human rights abuses, erosion of democracy and punishing Russia’s aggression.

Biden’s first step was to pause the flurry of activity during the final days of the Trump administration. Between January first and January 19th, Trump’s Treasury took 96 different sanctions actions across six different sanctions programs, an average of just over seven designees added per business day, sanctioning Iranian steel plants, Chinese Communist Party officials, Venezuelan regime officials and mistakenly, a pizza shop owner in Italy.

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Although a senior White House official said that a review of sanctions programs could take months, events quickly forced the Biden administration’s hand. A coup in Burma which began on the morning of February first, led to the administration’s first sanctions actions. Over the course of his administration’s first 100 days, Biden’s Treasury kept a steady a pace:

• Adding 107 designees

• Removing 60 designees

Whereas Trump’s January was focused on Iran and Venezuela, Biden’s priorities are very different. His top focus numerically, and perhaps politically has been Russia, but the coup in Burma has resulted in the most separate actions, eight in total (including one removal). Many of these were also done in coordination with allies, representing a return to the multilateral sanctions approach of the Obama years. Notably absent are any new Iran sanctions, with Foreign Policy Magazine reporting that the Biden team is instead actively evaluating delistings to revive the nuclear deal.

Another part of Biden’s approach has been to roll back some of Trump’s sanctions. While numbers don’t lie, sanctions delistings must be reviewed carefully. The narcotics delistings, while large, are part of a long-standing and apolitical sanctions program, which generally has large numbers of both delistings and additions. This sanctions program is also OFAC’s largest, with 2,296 designees currently listed on the SDNT and SDNTK lists (OFAC’s lists for narcotics sanctions).

Two of the delisting actions, however, did mark significant policy shifts:

• Prioritizing relief efforts: The removal of a terrorist label from Ansarallah, a Yemen based organization, was according to the Department of State “a recognition of the dire humanitarian situation in Yemen […] intended to ensure that relevant U.S. policies do not impede assistance […] Ansarallah leaders Abdul Malik al-Houthi, Abd al-Khaliq Badr al-Din al-Houthi, and Abdullah Yahya al-Hakim remain sanctioned.”

• Marking a more multilateral approach to sanctions: The US ended sanctions against members of the International Criminal Court in an action that was welcomed domestically and internationally, surprising observers only due to how long it took the Biden administration to reverse these extremely unpopular and controversial sanctions.

The above delistings were unusual primarily because delistings rarely receive press statements, however for those interested in sanctions trivia, OFAC did walk back two sanctions errors, one from the Trump administration and another one from Biden’s.

• The removal of an Italian pizza shop owner whose addition was a case of mistaken identity.

• The removal of a Burmese army unit due to accidental double-sanctioning. On March 22nd OFAC sanctioned the 33rd Light Infantry Division of the Burmese Army (33 LID). OFAC already sanctioned the 33 LID in 2018 under GLOMAG, and in March accidentally added a second 33 LID to the SDN database, instead of adding a second "program" to the initial listing. The original 33 LID had a unique ID of 24812 and the new one had a unique ID of 31471. Then on March 25th, OFAC removed the 2nd entry, and modified the first one, and provided public notice.

Methodology

To make these charts easier to read, we group similar lists under common themes. For example, OFAC does not have a sanctions list named “Narcotics” it has two lists, [SDNT] which is the “tag” it uses for sanctions under Narcotics Trafficking Sanctions Regulations, 31 C.F.R. part 536,​ and [SDNTK] which is the “tag” it uses for sanctions under Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598. To better understand OFAC’s “tags'“ and the relevant legal authorities, see OFAC’s site here.

Addresses and lists do not always tell the full story of why designees are added. For example several Pakistan-based individuals and organizations were sanctioned under the “tags” of [CYBER2] and [ELECTION-EO13848], however the reason for their designations was their assistance to the Russian government. Hence, we categorized these as Russia-themed sanctions.

On April 30th, OFAC migrated 39 names of Non-SDN Communist Chinese Military Companies (NS-CCMC) from a temporary PDF to OFAC’s standard file format, because OFAC is a good steward of data, and likely because they received hundreds of complaints, from us included. Although they were technically “added” to OFAC’s database on April 30th, as they were previously designated by the Trump administration, they are not new designations, .

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 900 watchlists, covering over 200 countries and six different categories (sanctions, export control, law enforcement most wanted, contract debarment, politically exposed persons and elevated risk). We update our watchlists every five minutes directly from issuing authorities.