If the US stops policing sanctions, can anyone else fill that role?
| Basel, Switzerland
The enforcement of international sanctions comes in many forms.
It can be as dramatic as French commandos intercepting a sanctioned Russian vessel at sea, or as political as Washington鈥檚 recent decision to sanction Cuban President Miguel D铆az-Canel and members of the Castro family. It can also be highly technical, such as when regulators penalize a bank for failing to identify a sanctioned Russian official because his name was spelled differently.
鈥淭he keys to effective sanctions are design, implementation, and 鈥� critically 鈥� enforcement to ensure the restrictions are viewed as credible,鈥� says Tom Keatinge, director of the Centre for Finance and Security at the Royal United Services Institute in London.
Why We Wrote This
A sanctions regime is only as good as its enforcement, experts say. With the United States showing erratic commitment to sanctioning Russia, among others, questions have emerged about whether the line can be held without Washington.
And whatever the particular method, experts concur: Without enforcement, sanctions are little more than symbolic gestures.
That is why the recent unpredictability of the United States with regard to sanctions 鈥� in particular toward Russia, but also regarding Iran, Venezuela, and Cuba, among others 鈥� has raised eyebrows among the powers upholding such regimes in the West. And it highlights the critical role that the U.S. plays within sanctions enforcement, and the difficulty that other parties that want to push sanctions would have if the Trump administration decides to reverse course and abandon its role as the foremost global sanctions police officer.
鈥淭he shift in sanctions focus by the United States poses challenges for both governments in Europe and the private sector globally,鈥� says Mr. Keatinge. 鈥淪anctions work best when countries are aligned, as this reduces loopholes and facilitates consistent implementation by the private sector. The varied action of the U.S. blunts this need for and benefit from alignment.鈥�
The major players
Modern sanctions enforcement is a complex and resource-intensive challenge. Last year alone, the United States, European Union, United Kingdom, and United Nations 鈥� the four major players in global sanctions 鈥� issued 265 sanctions-list updates and added nearly 4,000 new designations, according to LexisNexis analysis. Russia remained the focal point, while Iran again faced sanctions over its nuclear program.
Each new sanctions package issued by one of the four triggers a cascade of compliance obligations for financial institutions, shipping companies, insurers, exporters, and other businesses. Those parties must constantly monitor changes to ensure they are not dealing with sanctioned parties. A single listing can instantly freeze assets, prohibit transactions, and expose companies to serious fines.
The challenge of keeping pace is compounded by a fragmented global sanctions landscape and uneven enforcement capacity. In the United States, sanctions enforcement is largely centralized around the Treasury Department鈥檚 Office of Foreign Assets Control, which administers more than 30 sanctions programs and is staffed by several hundred officials. In Britain, the Office of Financial Sanctions Implementation has grown to over 130 full-time staff members since Russia鈥檚 invasion of Ukraine.
In the EU, while sanctions are agreed collectively in Brussels, enforcement remains largely the responsibility of national authorities, whose resources and expertise vary wildly. The European Commission has sought to narrow those disparities, however, by setting minimum enforcement standards and strengthening coordination.
鈥淭he EU is constantly breaking taboos with each new sanctions package,鈥� said Mihkel M盲rtens, a sanctions officer at the Ministry of Foreign Affairs in Estonia, during an online conference organized by the Center of European Policy Analysis. 鈥淚f you would have asked anyone working in EU sanctions five years ago whether the EU would start adopting anything that remotely resembles secondary sanctions, they would have just laughed.鈥�
鈥淭he only truly feared sanctions agency鈥�
Still, while Europe is widely seen as more dynamic than in the past, it can too easily be circumvented by Russia, says Mr. Keatinge. 鈥淒espite an increase in enforcement action in Europe, the United States OFAC remains the only truly feared sanctions agency.鈥�
Experts say that鈥檚 largely because of the magnitude of U.S. enforcement. Amir Fadavi, CEO of Sanctrust, which provides advice on sanctions compliance, says the watershed moment came in 2014, when French bank BNP Paribas agreed to pay nearly $9 billion to settle allegations that it had violated U.S. sanctions. That penalty sent a clear message that even non-U.S. institutions could face severe consequences for running afoul of Washington鈥檚 sanctions regime.
鈥淚t freaked everyone out in the global financial system,鈥� says Mr. Fadavi. 鈥淚t was a massive fine. ... All of a sudden U.S. sanctions were this extremely powerful tool.鈥�
As a result, he says, many institutions began building a margin of safety into their compliance programs. Rather than merely avoiding prohibited activity, they steered clear of transactions that fell into legal gray areas or where the cost of transactions outweighed the commercial benefit. The result was a broader retreat from higher risk markets like Afghanistan, Iran, and Syria.
鈥淭he private sector started doing things that are not necessarily required by sanctions law, but it became more of a risk-management practice,鈥� says Mr. Fadavi. 鈥淭hey are scared of getting it wrong.鈥�
Some call it sound risk management. Others view it as an overcompliance or the de facto privatization of sanctions enforcement. Whatever the label, the results, experts say, has been to transform banks, insurers, and shipping companies into key enforcers of sanctions because they fear getting sanctioned themselves over interactions with sanctioned actors.
No sanctions with the U.S.?
But the future of U.S. sanctions is foggy now, after the Trump administration began to show it might be wavering in its commitment to wield that particular club.
Throughout 2025, Western sanctions efforts focused on stripping Russia of oil revenues used to finance war in Ukraine. The EU and U.K. devoted unprecedented attention to Moscow鈥檚 鈥渟hadow fleet,鈥� blacklisting hundreds of vessels used to transport crude outside Western oversight and targeting the financial and commercial networks facilitating sanctions evasion.
But with the war with Iran and Tehran鈥檚 disruption of the fifth of the world鈥檚 oil supply that travels through the Strait of Hormuz, Washington began to offer 鈥渢emporary鈥� sanctions relief to Russia and Iran to try and control soaring energy prices.
鈥淪anctions are a political tool,鈥� says Mr. Fadavi. 鈥淚f a political leader doesn鈥檛 want to enforce it, there is very little you can do about it.鈥�
Europe and other U.S. allies can continue imposing sanctions and tightening enforcement, but experts say they cannot replace Washington, which remains the most powerful and best-resourced sanctions enforcer.
鈥淐an the EU go at it alone? They鈥檙e going to have to do what they can on their own if the U.S. does not step up and remain consistent,鈥� said Benjamin Schmitt, a senior fellow at the Center for European Policy Analysis, at the online conference.
But, he pointed out, sanctions work best when countries act in concert. Without consistent U.S. leadership, pressure on sanctioned actors weakens. Loopholes multiply and alternative trade and financing channels emerge.
鈥淚f the policymakers state out loud that there isn鈥檛 a threat, then you grow emboldened and you can continue business with those sanctions subjects,鈥� says Mr. M盲rtens. 鈥漈he really important thing about sanctions is, unless you enforce sanctions strongly, no one cares about them.鈥�
