Economic and trade sanctions have become one of the most widely used tools of U.S. foreign policy, aimed at promoting national security interests, deterring malign behavior, and influencing international conduct. These measures can range from targeted financial restrictions on individuals and entities to broad-based embargoes on entire countries. As global geopolitical dynamics shift, understanding the scope, enforcement, and compliance landscape surrounding sanctions is essential for both public and private sector actors.

In the United States, the enforcement of sanctions involves a network of federal agencies, each playing a distinct role in the design, implementation, and prosecution of sanctions-related actions. This article serves as an introduction to the architecture of U.S. sanctions enforcement and sets the stage for deeper dives into specific laws, cases, and emerging trends in future installments.

Key U.S. Agencies Involved in Sanctions Enforcement

Office of Foreign Assets Control (OFAC): As the principal agency administering U.S. sanctions programs, OFAC is part of the U.S. Department of the Treasury. It implements sanctions under national emergency powers and Congressional mandates by designating individuals, companies, and regimes for inclusion on the Specially Designated Nationals (SDN) list. OFAC also oversees the licensing process for authorized transactions and investigates violations of sanctions regulations.

Bureau of Industry and Security (BIS): Located within the U.S. Department of Commerce, BIS oversees the Export Administration Regulations (EAR), which govern the export of sensitive technologies, software, and goods. BIS coordinates closely with OFAC and other agencies when sanctioned entities are involved in technology transfer or export control violations.

Department of Justice (DOJ): The DOJ is responsible for investigating and prosecuting criminal violations of sanctions laws. It often works in collaboration with OFAC and BIS to pursue cases involving money laundering, fraud, and conspiracy related to sanctions evasion or export control breaches.

Department of State: While not a primary enforcement body, the State Department plays a key policy role in designing and supporting sanctions programs, particularly those involving arms control, international human rights, and foreign assistance restrictions. It also manages certain designations such as those related to terrorism and narcotics trafficking under statutory mandates.

Legal Authorities and Frameworks

Sanctions enforcement in the U.S. is underpinned by a mix of statutes, executive orders, and administrative regulations. The International Emergency Economic Powers Act (IEEPA) provides the President with authority to regulate commerce in response to national emergencies. The Trading with the Enemy Act (TWEA) is an older statute used in limited contexts, while the Global Magnitsky Human Rights Accountability Act authorizes sanctions against foreign officials involved in human rights abuses or corruption.

Additional legal frameworks such as the Countering America’s Adversaries Through Sanctions Act (CAATSA), and sector-specific legislation targeting countries like Iran, Russia, and North Korea, further expand the reach and specificity of U.S. sanctions policy. These laws are enforced through detailed regulations codified in the Code of Federal Regulations and administered through agency-issued guidance.

Whistleblowers and private individuals also play a significant role in supporting the U.S. government’s enforcement of global sanctions. Through programs such as the Department of the Treasury’s Office of the Whistleblower and provisions under the False Claims Act, individuals can report suspected violations of sanctions laws—including illicit transactions, concealed ownership, or deceptive trade practices. These tips can trigger investigations by federal agencies and, in some cases, lead to substantial penalties or settlements. Whistleblowers may be eligible for financial rewards if their information results in a successful enforcement action, creating a strong incentive for insiders and third parties to assist in uncovering sanctions evasion and enhancing the overall effectiveness of the enforcement regime.

Looking Ahead

Future articles in this series will examine how sanctions designations are made and challenged, review recent enforcement actions and litigation, and explore the increasing importance of compliance programs in both regulated industries and emerging sectors such as fintech and AI. We’ll also look at the growing role of multilateral coordination in sanctions enforcement and how global businesses can navigate overlapping regimes.

Understanding the full scope of sanctions enforcement is critical for mitigating risk and ensuring lawful operations in an interconnected economy. Stay tuned as we delve deeper into the mechanisms, policies, and consequences shaping the global sanctions landscape.