By The Data: 7 Actions Biden's Treasury Will Take In the First 100 Days
It's cliché to point out that sanctions have become a favorite tool in Washington, even if their effectiveness remains disputed. But they are easy and fast to announce, are implemented by the private sector globally, and generate significant press without sacrificing American lives.
The Biden administration will continue the Trump administration’s aggressive use of the Global Magnitsky Act, targeting human rights abuse and corruption globally. Biden’s Treasury, however, will emphasize multilateral actions and cooperation with the European Union (EU). It will increase pressure on Russia, China and North Korea, while easing or leveling off pressure on Iran and Cuba. Without further ado, here are 7 specific actions the Biden administration will take in its first 100 days:
International: Remove sanctions on two International Criminal Court prosecutors and terminate Executive Order 13928. This executive order, and its associated actions were widely reviled both at home and abroad, and are easy to remove.
Likely removal before June 2021: Two individuals sanctioned under Executive Order 13928.
Iran: Initiate steps to rejoin the Joint Comprehensive Plan of Action (JCPOA aka Iran Deal). The actual rejoining will not happen within 100 days, but the Biden administration will begin this process, which will include examining the delisting of over 700 Iranian entities, vessels and individuals. Most of the entities, vessels and individuals were sanctioned by the Obama administration, then removed as part of the JCPOA by the Obama administration, and then listed again by Trump’s Treasury Department. Biden’s Treasury Secretary will likely also terminate restrictive policies, including Treasury and State’s “Humanitarian Mechanism” for trade with Iran, which actually made it more difficult to send humanitarian goods to Iran. Still, considering the amount of political umbrage that President Obama received after the JCPOA, Biden will move slowly here, and attempt to negotiate new concessions from Iran.
Likely removal before January 2025: Around 700 entries, covering individuals, entities and vessels related to proliferation. The Trump administration holds the record for most names added to a watchlist in one action, but these are names that were removed in one action by the Obama administration as part of the JCPOA. These 700 names are the ones that are likely to come off.
Likely addition before January 2025: 100+ entities and individuals tied to corruption, human rights abuses and terrorism.
Russia: Begin large scale sanctions investigations regarding Russian illicit cyber activity, as well as human rights abuse, corruption and election interference. After Russian interference in US elections in 2016, congress forced the Trump administration to take action, but Trump’s Treasury only sanctioned 14 persons in Russia under Executive Order 13848, which targets election interference, and 16 persons under Executive Order 13757, which targets illicit cyber activity. There is no statute of limitations with sanctions - so expect these numbers to grow significantly. Additionally, after the poisoning of Russian opposition leader Alexei Navalny, Europe may be more amenable to US sanctions on energy pipeline Nordstream 2.
Likely addition before January 2025: 100 individuals and entities.
Belarus: catch up to European sanctions. The US currently lags behind Canada, the EU, France, Switzerland and the UK in terms of sanctions against Belarussian officials engaged in the suppression of democracy. Among those sanctioned by US allies is the leader of Belarus’ regime, Aleksandr Lukashenko.
Likely addition before June 2021: 30+ individuals tied to election suppression.
China: US will cancel Tiktok ban, increase human rights pressure on China. The deadline for Tiktok’s parent company, Bytedance, to sell Tiktok’s US operations is today (November 12th), but the US government has not communicated with Tiktok in several weeks, according to Tiktok. The Biden administration may be willing to repeal the proposed ban as leverage in negotiations with China, as the case for banning Tiktok remains more political than national security driven. Biden’s Treasury, however, will increase its use of Global Magnitsky Act sanctions in relation to China’s mass detention of Uighurs, suppression of democracy in Hong Kong and support of North Korea.
Likely addition before January 2025: 100+ individuals and entities under human rights and North Korea sanctions.
North Korea: Resume sanctions. Despite failing to achieve any disarmament from North Korea, the Trump administration paused North Korea sanctions writ-large, with its last DPRK-focused action taking place on March 2nd, 2020 and an update of existing sanctions on May 13th, 2020. The Biden administration has no incentives to keep this pause in place, and may look to be active on this portfolio to compensate for a slow-down related to Iran.
Likely addition before January 2025: 100+ individuals and entities under cyber, human rights and proliferation sanctions.
Venezuela and Cuba: Initiate working group to examine these two sanctions programs. Although Biden may be tempted to ease sanctions on these two countries to pursue diplomacy, strong political support for these programs in Florida, a crucial state for US presidential elections, may prevent Biden’s Treasury from rolling back either. Still, the United States is the only country in the world with sanctions on Cuba according to Castellum.AI data, and with only 5 individuals and 70 entities listed, it's not a large program. The US Department of State does have its own Cuba watchlists (seen here and here), and both of these are likely to be removed. These two lists would be easy to remove as they lack the legal power of sanctions and because they are also focused on a non-controversial sector (lodging: entries include hostels and spas).
Likely removal before January 2025: 100+ entries on State Department Cuba lists.
Likely addition before January 2025: 50+ individuals and entities for suppression of democracy in Venezuela.
