In light of the issues described above, this paper makes the following recommendations for policymakers and those monitoring sanctions policy, intended to enhance the effectiveness of sanctions, mitigate unintended consequences and address enforcement challenges. The recommendations and the above analysis are drawn from a 2024 Chatham House conference on sanctions and the authors’ own research.
Sanctions should be justified by a clear objective
US, European and other Western governments (largely from the Global North) imposing sanctions need to have specific reasoning, be clear on their objectives, and communicate these transparently with allies as well as their targets. Having a limited policy goal tied to proposed sanctions that is publicly stated from the beginning of the process, and communicating this to all parties, is essential for developing trust and legitimacy. Moreover, it provides a clear path for negotiating (or not) an exit ramp for sanctions.
Ensuring that sanctions are justified in measurable and specific ways with a clearly articulated policy objective requires states to resist using sanctions as a limitless instrument for multiple, potentially unrealistic foreign policy problems. Such an approach would change the emphasis in the design and justification of sanctions to be more specific and shift the use of sanctions to be proactive rather than reactive. Throughout the process, it is also essential for sanctioning entities to maintain clarity of purpose to assess their effectiveness. This effort, however, has become complicated by the ‘intermestic’ nature of sanctions, particularly in the US, in which well-organized constituencies can remain vigilantly inflexible on sanctions policies, and congress is becoming increasingly active in sanctions policy.
Coordination with allies is essential
Sanctions are more effective when coordinated across multiple actors – among allies or within political and economic forums such as the G7 or the EU. Coordination on strategy, targets and third-country engagement to build support for sanctions regimes is essential, along with synchronization on implementation, enforcement and litigation. Clearer objectives and coordination require a more united front among concerned countries – even non-sanctioning ones – and can increase pressure on the targeted regime while providing opportunities to mitigate negative economic consequences for global markets. One of the difficulties that has cropped up is coordinating and enforcing sanctions on Russia and Venezuela through third countries and cracking down on the fleets of shadow tankers shipping embargoed oil.
While there are challenges in agreeing to and coordinating sanctions through multilateral forums in today’s geopolitical climate, it is still possible to widen sanctions coalitions and deepen cooperation among allies. Effective examples of this include simultaneous UK and US sanctions on the trade of Russian metals in 2024, and joint UK and EU third-country visits that have helped to identify and address the frequent use of third countries to maintain exports to sanctioned countries. Similarly, the Dutch foreign ministry’s effort to consolidate sanctions information and improve communication is an important public step. Similar efforts can be replicated by and across individual governments.
The vetting of sanctions, and dialogue across affected stakeholders, can be improved
Developing a regular, potentially annual multi-stakeholder system to review sanctions processes and their intended and unintended consequences is essential. The first priority should be communication and coordination with governments that have close ties to sanctioning governments – including those who have supported sanctions and those who have not – to review the impact of sanctions. This is also true for secondary sanctions, described above.
A central part of this process should be the development of a metric to measure both the success of sanctions in meeting their (reduced and clear) objectives and their unintended consequences. The latter should include both deepening poverty and humanitarian suffering among local populations, as well as the consolidation of power among regime allies in the sanctioned country, reduced independent economic space and, internationally, cooperation among regimes opposed to Western objectives and norms. Guiding such a discussion will require a more detailed and rigorous framework for evaluating those effects.
While such research can be fraught with political, ideological and methodological concerns, there are a few areas in which it could and should start. The first step should be the collection and publication of comprehensive sanctions details at the moment when such measures are imposed. Pre-sanctions data collection should include poverty rates, inequality – disaggregated by gender, age and race/ethnicity – and access to healthcare and a basic minimum basket of food and nutrition. Doing so will establish a baseline that can be compared to later conditions post-sanctions and, if detailed over time, can help identify the different effects of international sanctions on the target regime’s economic and social policies and corruption. Such an effort should also measure extant state social programmes as a percentage of the national state budget dedicated to public goods – such as education and healthcare – and social safety-net programmes. Those baseline data can be used to understand pre- and post-sanctions impacts, specifically target governments’ responses, and provide a window into how effectively targeted governments attempt – or not – to cushion the impact of sanctions on their citizens.
Such a process should also include baseline data, as well as longitudinal analysis of the flow, distribution and access to humanitarian support. Through local surveys and interviews with non-partisan humanitarian organizations, the research can begin to detail the effectiveness of humanitarian carveouts. A refrain often heard from multilateral organizations (such as the UN World Food Programme) and NGOs is that despite supposed carveouts for food and medicine, sanctions suppress donations and support for such efforts often trails off out of overcompliance with sanctions. Discussion and development of sanctions policies and the measurement of their impact should include representatives of relief organizations that seek to deliver assistance to affected populations in sanctioned countries and consider the risk of overcompliance. Effective communication between policymakers, humanitarian NGOs and multilateral organizations would help to tackle challenges that arise because of sanctions.
Separately, there should also be regular vetting sessions – as has already started – among policymakers and affected businesses, in the design, implementation and enforcement of sanctions. Improving dialogue with both the private sector and NGOs, as well as considering business and humanitarian concerns in relation to sanctions regimes, will help to address issues of flawed design and enforcement, alleviating some of the key concerns that arise due to sanctions’ impacts on citizens.
Sanctions should be part of a broader strategy
Sanctions work best when they are employed as part of a broader strategy that includes diplomatic, economic and humanitarian levers. Applying sanctions in conjunction with activities such as wider external pressure campaigns, using UN institutions and diplomatic tools, can further isolate target regimes diplomatically as well as economically. Sanctioning states should also apply internal pressure through supporting civil society and humanitarian organizations, helping independent organizations and voices have the resources to sustain civic space and anti-poverty assistance within the target country where possible.
Coordination between multilateral and unilateral sanctioning entities and stakeholders attempting to mediate should be a central component of that strategy. A 2022 article by Thomas Biersteker, Rebecca Brubaker and David Lanz examined the relationship between UN sanctions and international mediation. Their conclusion that UN sanctions can both ‘complicate and complement UN mediation efforts’ demonstrates the risks of even consensus-based multilateral UN sanctions. In the cases they examined, multilateral sanctions can close mediation space and undermine genuine consent. While not included in their analyses, their concerns are especially relevant to unilateral sanctions by individual countries, which often have their own policy objectives, targeted individuals and organizations – including parties that should be at the table in any mediation effort – and their own domestically driven factors.
Too often, sanctions remain inflexibly locked in place, a result of insufficient early planning, or lack thereof. The imposition of sanctions should require a broader process of review and policy steps if they fail within a defined time to achieve their objectives.
Even in their initiation, sanctions development should articulate and prepare a ‘plan B’ for what happens if the sanctions do not achieve their intended ends. Too often, sanctions remain inflexibly locked in place, a result of insufficient early planning, or lack thereof. The imposition of sanctions should require a broader process of review and policy steps if they fail within a defined time to achieve their objectives. Such an effort should not be a binary choice of either/or sanctions, but rather a multi-pronged definition of sanctions policy. It should define alternative or ramped up diplomatic strategies, military assistance and attempts to create an enabling environment for change, engaging local populations on issues of common interest where possible.
Untangling the impacts of sanctions on local populations
Implementing carveouts for humanitarian assistance can help to untangle the impact of sanctions on local populations and ensure principled humanitarian action. While there is a tension between sanctions and humanitarian actions, the last couple of decades have brought about progress on designing and shaping sanctions regimes that are much more targeted and avoid sweeping impacts on sanctioned populations. For example, the US’s Office of Foreign Assets Control has made strides in meeting with affected NGOs and multilateral organizations to explain the limits and intent of US sanctions in specific countries.
The impacts of sanctions on humanitarian action are best reduced by the inclusion of different kinds of safeguards. The humanitarian sector considers these to be most effective when they take the form of specific, publicly detailed exceptions or exemptions, which act as carveouts for as broad a range of humanitarian actions as possible. Assigning sanctions officials from the relevant government agencies to meet with and explain the limits and – when they occur – carveouts and liberation of sanctions to affected investors, governments, donors and multilateral organizations – as the US has started to do – is an important step.
Countering the axis of the sanctioned and addressing accusations of hypocrisy
Given the shifting geopolitical dynamics that have occurred in recent years and continue to evolve, policymakers are also confronted with the need to counter the ‘axis of the sanctioned’ as well as accusations of hypocrisy and double standards in their foreign policy decisions. Claims of the hypocrisy of sanctions not only undermine their legitimacy and require states to address such criticism, they also raise the risk of an escalation of sanctions globally among competing blocs and countries, as we have seen with Russia and China. As such, governments in the US, EU and UK – the most prolific sanctioners – should adopt a more collaborative approach towards working with partners in the ‘Global South’, which are at the sharp end of the results of economic coercion by the US. A particular focus should be on secondary sanctions, which should be applied with caution for their often-unintended effects of rewarding rogue regimes and their economic interests.
Developing a checklist of best practices in sanctions development and enforcement
When beginning to develop and design sanctions, policymakers must consider how they will implement them in the long term. Where multiple government entities are involved in sanctions enforcement, there should be a common vision and a ‘whole-of-government approach’ to enforcement efforts.
Having a strong compliance culture is also key. This depends on the ability of states to credibly threaten potential punishments to increase the deterrent effects of sanctions, as well as engage with industry and the public to foster compliance. Lacking that long-term vision (and defence) raises the risk of sanctions fatigue that can undermine the intended goals and, in the end, strengthen the intended target. Non-public actions are equally important to compliance efforts. Measures such as cautionary letters can provide policymakers involved in enforcement and compliance with a means to collaborate with affected economic stakeholders. The messaging around enforcement should highlight the activity that has prompted such action, detail how compliance failures occurred and share lessons for the future.
Ensuring that enforcement actions articulate compliance expectations and communicating these to affected stakeholders – especially small and medium-sized enterprises – will ensure broader compliance and cooperation – and help make sure that sanctions do not overly penalize small and medium-sized enterprises in sanctioned or sanctioning countries.
