Economic Sanctions: Agencies Assess Impacts on Targets, and Studies Suggest Several Factors Contribute to Sanctions' Effectiveness

The United States maintains dozens of economic sanctions programs to counteract activities that threaten U.S. national interests. There are currently 20 country-based or country-related sanctions programs, according to lists of sanctions programs published by Treasury and State (see map). Additional countries may also be affected by sanctions programs that target entities regardless of their geographic location, such as counter-narcotics sanctions. Treasury, State, and Commerce, among other agencies, coordinate to implement these programs. Sanctions may place restrictions on a country's entire economy, targeted sectors of the economy, or individuals or corporate entities. Reasons for sanctions range widely, including support for terrorism, narcotics trafficking, weapons proliferation, and human rights abuses. Economic restrictions can include, for example, denying a designated entity access to the U.S. financial system, freezing an entity's assets under U.S. jurisdiction, or prohibiting the export of restricted items. GAO was asked to review issues related to the implementation and effectiveness of economic sanctions. Among other things, this report (1) examines the extent to which U.S. agencies assess the effectiveness of sanctions, and (2) identifies factors that have been shown by publicly available studies to contribute to the effectiveness of economic sanctions. GAO reviewed documents and interviewed officials at Treasury, State, and Commerce and in the U.S. Intelligence Community. GAO also reviewed academic studies that used rigorous statistical methods to analyze the impact and effectiveness of economic sanctions across many sanctions programs.

The Departments of the Treasury (Treasury), State (State), and Commerce (Commerce) each undertake efforts to assess the impacts of specific sanctions on the targets of those sanctions. For example, Treasury and State both analyze or compile information on sanctions programs' impacts, such as on a target country's economy. In addition, Commerce assesses prospective impacts of some sanctions on targeted countries and others. According to Treasury and State officials, the agencies also use Intelligence Community assessments to gauge sanctions' impacts. However, agency officials cited several difficulties in assessing sanctions' effectiveness in meeting broader U.S. policy goals, including challenges in isolating the effect of sanctions from other factors as well as evolving foreign policy goals. According to Treasury, State, and Commerce officials, their agencies have not conducted such assessments on their own. However, they stated that agency assessments of sanctions' impacts often contribute to broader interagency discussions that examine the effectiveness of sanctions in achieving policy goals.

The academic studies GAO reviewed suggest that several factors have contributed to more-effective sanctions. Studies examining factors that contribute to the effectiveness of sanctions in changing targeted countries' behavior provided evidence that sanctions have been more effective when (1) they were implemented through an international organization (e.g., the United Nations) or (2) the targeted countries had some existing dependency on, or relationship with, the United States, such as a trade or military relationship. In addition, studies examining factors that increased sanctions' economic impact provided evidence that the impact has generally been higher when the sanctions were more comprehensive in scope or severity, or—similar to the findings on effectiveness in changing behavior—were imposed through an international organization. Sanctions may also have unintended consequences for targeted countries, such as negative impacts on human rights or public health. In some studies, larger economic impacts were associated with more unintended consequences.

The United States engages in multifaceted programs to further U.S.  interests abroad. One of these facets is economic sanctions. The United  States maintains dozens of economic sanctions programs that can be  implemented in conjunction with diplomatic or military efforts to counteract  activities that threaten U.S. national interests. The U.S. Departments of  the Treasury (Treasury), State (State), and Commerce (Commerce),  among others, coordinate to implement these programs.

Sanctions may place restrictions on a country’s entire economy, targeted  sectors of its economy, or individuals or corporate entities for reasons  such as support for terrorism, narcotics trafficking, weapons proliferation,  or human rights abuses. Economic restrictions can include, for example,  denying a designated entity access to the U.S. financial system, freezing  an entity’s assets under U.S. jurisdiction, or prohibiting the export of  restricted items. The United States may implement sanctions unilaterally  or may work with other countries—for example, in the United Nations  Security Council or with the European Union—to sanction a target  multilaterally.

The United States employs sanctions to serve various purposes. For  example, in 2014, the United States imposed sanctions on Russia in  response to the actions and policies of the Russian Federation  government, including its purported annexation of the Crimea region of  Ukraine. These sanctions targeted, among others, Russian Federation  officials and persons responsible for, or complicit in, certain activities with  respect to Ukraine. In recent years, the United States has also imposed  or expanded sanctions targeting Iran, North Korea, Syria, and Venezuela,  among other countries.

You asked us to review issues related to the implementation and  effectiveness of economic sanctions. This report (1) describes how  Treasury’s, State’s, and Commerce’s roles in implementing U.S.  sanctions authorities are identified; (2) examines the extent to which U.S.  agencies assess the effectiveness of sanctions; and (3) identifies factors  that have been shown by publicly available studies to contribute to the  effectiveness of economic sanctions  To describe how Treasury’s, State’s, and Commerce’s roles in  implementing U.S. sanctions authorities are identified, we reviewed legal  authorities (e.g., executive orders and statutes) that authorize various  sanctions programs, and interviewed agency officials.

To examine the extent to which U.S. agencies assess the effectiveness of  sanctions, we interviewed officials from Treasury, State, Commerce, and  the Intelligence Community. We also obtained and reviewed agency  assessments for sanctions programs related to Burundi, North Korea,  Russia, and Somalia. We selected these country-based and country- related sanctions programs on the basis of the numbers of entities  recently sanctioned under each program, to reflect a range from low to  high and to obtain diversity in the types and numbers of authorities  underlying the program. We used these assessments to gain insight into  the types of analysis conducted.

To identify factors that have been shown by publicly available studies to  contribute to the effectiveness of economic sanctions, we conducted a  literature search to identify studies that assessed factors that contributed  to the effectiveness of sanctions in changing behavior or that increased  the economic impact of sanctions. While we focused on the effectiveness  of sanctions in coercing states to change their behavior, sanctions may  have other goals, including constraining a target state’s access to  resources or enforcing international norms. To identify studies, we (1)  searched various databases; (2) conducted “snowball sampling,” identifying new studies cited in papers that we had previously identified;  and (3) asked academic experts to validate our list of studies and  recommend additional studies that met our criteria. We ultimately  selected 17 studies for further review, each of which (1) was a peer- reviewed publication or academic working paper, (2) entailed a sufficiently  rigorous statistical analysis of many sanctions, (3) focused on the  effectiveness or impact of sanctions and included U.S. sanctions, and (4)  was published between 2004 and October 2018 and relied on relatively  recent data. We conducted detailed reviews of the selected studies’  research methodology, including the studies’ data, outcome measures,  control variables, limitations, and analytic techniques. We also  summarized each study’s major findings and the extent to which the  findings were supported by the study’s methods. We synthesized the  findings, and we categorized and aggregated the factors relevant to the  effectiveness of sanctions. Three academic experts with significant  publications in sanctions literature reviewed a draft of our summary of the  literature. These experts agreed with our overall findings and provided  additional comments and suggestions, which we incorporated as  appropriate. See appendix I for a more detailed discussion of our report’s  scope and methodology and see appendix II for a list of the studies we  reviewed.

We conducted this performance audit from May 2018 to October 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Sanctions provide a range of tools that Congress and the President may  use to seek to alter or deter the behavior of a foreign government,  individual, or entity in furtherance of U.S. national security or foreign  policy objectives. For example, sanctions may be used in response to  human rights abuses, weapons proliferation, or occupation of a foreign  country; ultimately seeking to change the behavior of those perpetrating  these offenses. Sanctions may include actions such as limiting trade;  blocking assets and interest in assets subject to U.S. jurisdiction; limiting  access to the U.S. financial system, including limiting or prohibiting  transactions involving U.S. individuals and businesses; restricting private  and government loans, investments, insurance, and underwriting; and  denying foreign assistance and government procurement contracts.

Sanctions can be comprehensive or targeted.

Comprehensive sanctions. Generally, comprehensive sanctions  include broad-based trade restrictions and prohibit commercial activity  with an entire country. Examples of comprehensive sanctions include  U.S. sanctions against Iran and Cuba.

Targeted sanctions. Targeted sanctions restrict transactions of and  with specific persons or entities. For example, the U.S. sanctions  program related to Somalia targets persons engaging in acts  threatening the peace, security, or stability of Somalia. Sectoral  sanctions are a form of targeted sanctions directed at a specified  sector, or sectors, of a target’s economy. For instance, Executive  Order 13662 authorized sanctions targeting certain sectors of the  Russian economy as might later be determined by the Secretary of  the Treasury in consultation with the Secretary of State, such as the  financial services, energy, mining, and defense and related materiel  sectors. The United States also uses supplementary sanctions, known  as secondary sanctions, which target third-party actors doing  business with, supporting, or facilitating targeted regimes, persons,  and organizations. For example, in February 2017, Treasury imposed  sanctions against 13 individuals and 12 entities, including persons  outside Iran, for their involvement in or support for Iran’s ballistic  missile program, as well as for acting for or on behalf of, or providing  support to, Iran’s Islamic Revolutionary Guard Corps-Qods Force.

There are currently 20 country-based or country-related sanctions  programs, according to lists of sanctions programs published by Treasury  and State. The sanctions may target the governments of these countries  or individuals and entities. Figure 1 shows country-based and country- related U.S. sanctions programs as of July 2019.

Implementing Agencies for U.S. Economic Sanctions

Treasury, State, and Commerce, as well as various other U.S. agencies,  play roles in implementing sanctions.

Treasury implements sanctions by taking actions such as designating  entities for the application of sanctions. These sanctions may include  blocking entities’ access to U.S.-based assets, prohibiting them from  engaging in financial transactions in the United States, and restricting  access to U.S. financial services. Treasury’s Office of Foreign Assets  Control (OFAC), which is part of the Office of Terrorism and Financial  Intelligence (TFI), has primary responsibility for Treasury’s sanctions  implementation, according to Treasury. TFI is charged with safeguarding  the U.S. financial system against illicit use and combating rogue nations,  terrorist facilitators, weapons of mass destruction proliferators, money  launderers, drug kingpins, and other national security threats. As part of  its implementation of sanctions, OFAC publishes a list, known as the  Specially Designated Nationals List, of individuals, groups, and entities  whose assets in the United States are blocked and with which U.S.  persons are prohibited from dealing. The addition of an individual, group,  or entity to this list is referred to as a sanctions designation. Entities or  groups listed include those owned or controlled by, or acting for or on  behalf of, targeted country governments. OFAC also lists individuals,  groups, and entities, such as terrorists and narcotics traffickers,  designated under targeted sanctions programs that are not country  specific. OFAC may also issue licenses, general or specific, to permit  activities that would otherwise be prohibited under a sanction. For  example, OFAC has issued a general license to allow nongovernmental  organizations to engage in not-for-profit activities in Syria in support of  humanitarian projects, democracy-building, education, and  noncommercial development projects directly benefitting the Syrian  people. According to Treasury, OFAC participates in all aspects of  sanctions implementation, including, targeting, outreach to the public, and  compliance. OFAC also enforces sanctions by conducting civil  investigations of sanctions violators and working with law enforcement  agencies.

State implements economic and other sanctions through a variety of  actions, such as implementing sanctions-related controls on defense  exports, restricting foreign aid, implementing arms embargoes pursuant to  United Nations Security Council resolutions, and restricting visas. State’s  primary sanctions coordination office is the Office of Economic Sanctions  Policy and Implementation (SPI), which is part of the Division for Counter  Threat Finance and Sanctions in State’s Bureau of Economic and  Business Affairs. According to State, SPI is responsible for developing  and implementing foreign policy–related sanctions adopted to counter  threats to national security posed by particular activities and countries. In  addition, according to State, SPI builds international support for  implementing sanctions, provides foreign policy guidance to Treasury’s  OFAC and Commerce’s Bureau of Industry and Security on sanctions  implementation, and works with Congress to draft legislation that  advances U.S. foreign policy goals in these areas. Further, according to  State, SPI works to remove sanctions when appropriate to reward and  incentivize improved behavior or demonstrate U.S. support for newly  established democratic governments.

Although SPI is State’s primary sanctions coordinating office, other State  bureaus, offices, and overseas posts may have significant roles in  sanctions implementation, depending on the sanctions program. Some  functional bureaus interact with OFAC within their areas of expertise. For  example, according to State, the Bureau of International Security and  Nonproliferation has expertise on missile, chemical, and biological  proliferation as well as how to counter proliferation. The bureau assists in  developing sanctions programs and designating sanctions targets under  nonproliferation law, according to State. Also, the Bureau of  Counterterrorism and Countering Violent Extremism takes part in  developing and evaluating sanctions policy as well as helping target  entities for sanctions under various authorities, including an executive  order targeting those that commit or support terrorism and the Foreign  Terrorist Organization section of the Immigration and Nationality Act,  according to State. Additionally, the Bureau of International Narcotics and  Law Enforcement Affairs uses its expertise in drug trafficking, corruption,  and crime to assist in selecting targets for counternarcotics sanctions,  transnational criminal organization sanctions, and corruption-related  sanctions under human rights law, according to State. SPI also works  with State’s regional bureaus, such as the Bureau of African Affairs;  country offices; and overseas posts to develop potential targets for given  sanctions programs, such as those in Somalia and Burundi.

Both Treasury and State also have intelligence offices that provide the  sanctions-implementing offices with information to facilitate sanctions  targeting and enforcement efforts and developing new sanctions policy.

Treasury’s Office of Intelligence and Analysis (OIA). TFI’s OIA is  responsible for TFI’s intelligence functions as well as for integrating  the Treasury Department into the larger Intelligence Community and  providing support to both Treasury leadership and the Intelligence  Community.

State’s Bureau of Intelligence and Research (INR). INR’s primary  mission is to provide all-source intelligence and analysis to serve U.S.  diplomacy. INR provides independent analysis of events to State  policymakers as well as officials throughout the U.S. government and  coordinates with other intelligence agencies to obtain relevant  information to inform State policymakers. For example, INR’s  analytical offices and its Sanctions Support Team, when requested,  gather and provide information—both classified and open sourced— on sanctions targets to policy officials at State and Treasury.

In addition to OIA and INR, other U.S. intelligence agencies provide  support to the sanctions-implementing agencies.

Commerce implements sanctions by restricting licenses for exports,  reexports, and transfers (in-country) involving U.S.-origin items— commodities, software, and technology—subject to its jurisdiction and  destined for sanctioned persons, entities, and destinations. Through its  export licensing process, Commerce’s Bureau of Industry and Security  (BIS) restricts sanctioned countries’ and persons’ access to U.S. items.  BIS also enforces export controls through its Office of Export  Enforcement, which conducts criminal and administrative investigations of  potential violations of export regulations.

Other U.S. agencies with roles in sanctions implementation include the  Departments of Defense, Energy, Homeland Security, and Justice. The  agencies involved and the extent of their involvement depend largely on  their area of expertise. The following are a few examples of how other  agencies are involved with sanctions:

The Department of Defense restricts arm sales and other forms of  military cooperation and is involved in decisions regarding export  licenses.

The Department of Energy assists in implementing nonproliferation  sanctions.

The Department of Homeland Security’s Customs and Border  Protection helps assure that shipments to and from sanctioned  countries and entities do not leave or enter the United States.

The Department of Justice investigates and prosecutes violations of  sanctions and export laws and provides legal reviews of sanctions’  designations.

Treasury’s, State’s, and Commerce’s Roles in Implementing Sanctions Are Established by Statute, Executive Order, or an Interagency Process

The roles of Treasury, State, and Commerce in implementing sanctions  are assigned either directly by the statute or executive order authorizing  the sanctions or through an interagency process and agreement. Some  statutes and executive orders designate an agency to serve as the  primary agency for sanctions implementation and also designate one or  more agencies to support the primary agency through consultation. For  example, Executive Order 13570, Prohibiting Certain Transactions With  Respect to North Korea, authorizes Treasury, in consultation with State,  to carry out actions to employ all powers granted to the President by  specified laws to carry out the purposes of the order. While some  statutory authorities may designate specific agencies for implementation,  most do not make such designations but rather delegate the authority to  do so to the Office of the President, according to State officials. Agency  officials also noted that they are often involved in drafting new sanctions  legislation and, if the statute will designate specific agency roles, are able  to advise lawmakers regarding the selection of the primary agency for  implementing sanctions.

When a statute or executive order authorizing sanctions delegates  authority to the Office of the President, specific agency roles are assigned  through an interagency process at the National Security Council (NSC).  According to State officials, the NSC’s Principals Coordinating Committee  discusses and assigns agency roles in a sanctions program. According to  State officials, most of the committee’s decisions about agency roles are  made at the staff level, and the actual principals become involved only if  there is a disagreement among the agencies’ staffs. State officials told us  that each agency’s area of expertise and its available resources factor  into the selection of an agency to lead implementation of a particular  sanctions authority. For example, according to a State official, Treasury is  often the lead for country-based sanctions, because these programs often  focus on international financial transactions, while State usually serves as  the lead for sanctions requiring more specialized knowledge, such as  those relating to weapons of mass destruction and nuclear  nonproliferation. State officials added that there is usually very little, if  any, disagreement among the agencies regarding whether they should  have primary or consultative roles. Once a decision is made, the  President typically issues a delegation memo assigning responsibility for  implementation of elements of the sanctions authority to each agency  involved, according to Treasury officials.

Treasury, State, and Commerce each provide publicly available  information about the sanctions they implement and the authorities  underlying those sanctions.

Treasury. OFAC maintains a publicly available list of all sanctions  laws and executive orders that Treasury has a role in implementing.  The list is organized by sanctioned country and functional program.

For each country-based, country-related, or functional program, the  entry in the list includes a discussion of statutory authorities, executive  orders, and regulations under which the program is implemented.  According to Treasury officials, OFAC staff track and update changes  in U.S. sanctions policy as needed and post new sanctions  information to the agency’s website as soon as a sanction is  approved.

State. SPI also maintains publicly available lists of the major  sanctions laws and executive orders that State has a role in  implementing. These lists are organized by sanctioned country and by  functional program. According to State officials, SPI typically  updates these lists when authorities are established or rescinded and  periodically reviews and updates the web pages where it posts the  lists. According to State officials, the lists are not intended to be  comprehensive and are meant only to give the reader a general  understanding of some of State’s high-profile sanctions programs and  to provide an initial resource for information and recent actions.

Commerce. BIS produces a compilation of legal authorities pertaining  to the administration of export controls under the Export  Administration Regulations. Unlike Treasury and State’s lists,  Commerce’s compilation comprises all of Commerce’s legal  authorities to control exports, reexports, and transfers (in-country).  These include executive orders, laws, and presidential declarations  authorizing controls related to national security, chemical and  biological weapons, and nuclear nonproliferation reasons, as well as  controls for foreign policy–related sanctions. According to Commerce  officials, the compilation is updated annually to reflect additions to, or  deletions of legal authorities. BIS also issues rules amending the  Export Administration Regulations to implement new executive orders  and statutory and other legal authorities on a frequent basis, at times  within a few days of the announcement or enactment of the underlying  authority. According to Commerce officials, publishing rules amending  the Export Administration Regulations provides the public with timely  notice of changes to Commerce’s sanctions authorities and actions  taken pursuant to these authorities.

Agencies Assess Sanctions’ Impacts but Cited Difficulties in Assessing Sanctions’ Effectiveness in Achieving Broader Policy Goals

Treasury, State, and Commerce assess potential and observed impacts  of specific sanctions, but officials stated they do not conduct agency  assessments of the effectiveness of sanctions in achieving broader U.S.  policy goals and cited various difficulties in doing so. Each agency’s  sanctions implementation offices rely mainly on assessments performed  by the Intelligence Community, including Treasury’s OIA and State’s INR.  These assessments analyze the impacts of specific sanctions on a  particular aspect of the sanction’s target—for example, the sanctions’  impact on the target country’s economy or trade, according to agency  officials. However, these assessments do not analyze sanctions’ overall  effectiveness in achieving broader U.S. policy goals or objectives, such  as whether the sanctions are advancing the national security and policy  priorities of the United States, according to Treasury officials. Treasury,  State, and Commerce have not conducted such broader assessments on  their own, and agency officials cited a variety of difficulties related to  doing so. However, according to Treasury, State, and Commerce, agency  assessments of sanctions’ impacts often contribute to broader  interagency discussions, typically coordinated through the NSC, that  examine the effectiveness of sanctions in achieving policy goals.  According to agency officials, an NSC-led process allows the U.S.  government to draw upon multiple agencies’ inputs and perspectives, and  to consider these issues in the larger policy context, because sanctions  are often only one element of broader government-wide strategies to  achieve U.S. policy goals.

Treasury, State, and Commerce Assess Specific Sanctions’ Impacts on Targets and Receive Assessments from Other Intelligence Agencies

Treasury has assessed both the observed and potential impacts of  specific sanctions designations on various aspects of targets, such as a  target country’s economy. Treasury’s intelligence component, OIA,  conducts the majority of these impact assessments and produces analytic  papers on sanctions’ impacts, according to officials. OIA officials stated  that the type of analysis varies depending on the purpose or nature of the  assessment. For example, some analytic papers focus on the overall  economic impact of the sanction on the target country, while others  examine the impact on a specific target, such as an entity or group of  entities. According to Treasury officials, the office has conducted both  short-range and long-range analyses of sanctions’ impacts at both the  country-specific and the authority-specific level. Treasury officials said  that the frequency of assessments conducted for a particular country or  authority varies according to the sanctions program’s size and relative  importance to current U.S. policy goals. OIA officials reported that the  Under Secretary for TFI requires that impact assessments be conducted  prior to an action as part of the targeting process and retrospectively after  a designation takes place. According to Treasury officials, TFI, including  OIA, considers conducting such impact assessments to be part of OIA’s  mission. OIA officials noted that OIA, as well as TFI more broadly,  considers understanding sanctions impact to be integral to developing  sanctions policy and making targeting decisions.

OIA officials stated that their impact assessments are circulated within  Treasury and their broader analytic papers are circulated within the  Intelligence Community and interagency. In addition, OFAC officials  reported that they request impact assessments from OIA whenever new  sanctions targets are being considered. OFAC officials stated that OIA’s  impact assessments are an integral part of any targeting matrix prepared  by OFAC’s Office of Global Targeting. According to OFAC officials, the  type of assessment requested depends on the issue, program, and  target. The requested assessments may include, for example, determining whether a target has assets in the United States to an  extent that sanctions would be impactful,  identifying the holdings of a given target globally and its interactions  with the United States, or analyzing the second- and third-order effects of a potential sanctions  designation.

OFAC officials said that these assessments are also used in risk- mitigation planning. For example, if an assessment revealed that a  particular sanction would lead to an undesirable consequence, such as  blocking important medical supplies or other humanitarian items, OFAC  might take preemptive measures to mitigate that undesirable  consequence through a general license or other available tools.

Treasury’s Office of International Affairs also prepares some  assessments of sanctions’ impacts. According to Treasury officials, the  Office of International Affairs occasionally conducts macroeconomic  assessments of the impact of specific sanctions to inform TFI  policymaking. A senior Office of International Affairs official reported that  most of the office’s macroeconomic analyses of sanctions’ impacts are  focused on the potential impact on economic growth and financial stability  in the target country. In addition, OFAC officials stated that the Office of  International Affairs often participates in agency discussions and may  provide verbal or written assessments of sanctions’ impact on foreign  partners’ industries and markets as well as on U.S. companies.

State conducts some assessments of the impact of sanctions on their  intended targets. INR produces most reports on sanctions impact, which  are based on all sources of information (i.e., classified and open source).  According to INR officials, these reports are often produced at the request  of State policymakers, and occasionally coordinated with the broader  Intelligence Community. INR facilitates the review of sanctions’ impacts  on particular governments or other areas of interest at the request of, or  in partnership with, State’s regional and functional bureaus. According to  INR, most of INR’s intelligence support responds to specific questions  and requests, such as whether a particular company is still operating in a  sanctioned country. According to State officials, INR provides responses  to requests in written products, such as formal INR or Intelligence  Community assessments, or more informally through channels such as  oral briefings or email responses. INR officials noted that written products  often inform interagency discussions on sanctions at the NSC, since  questions asked at State often become relevant to broader policy  discussions.

Other State entities have also examined the impact of sanctions. In 2016,  State’s Office of the Chief Economist, responding to a request from SPI,  analyzed the economic impact of targeted sanctions on Russian firms.  According to SPI officials, they commissioned the study because they  wanted to understand the specific impact of sanctions on a country that  was already facing economic challenges, given that sanctions were  among several foreign policy tools used to address Russian behavior.  According to SPI officials, this was the only analysis of sanctions impact  that SPI had requested of the Office of the Chief Economist in the past 5  years. In addition, some embassies have used cables to State  headquarters to report on the impact of sanctions. According to State,  most such information on a sanction’s impact is captured in a sentence or  two as part of a cable focused on other issues. However, embassies in  countries where sanctions are imposed on the host government (or  nearby governments) often dedicate significant time to reporting on the  impact of sanctions and how they affect broader foreign policy, according  to State officials. For example, the U.S. embassy in Seoul produced a  series of cables in 2017 and 2018 detailing observed impacts of sanctions  on the North Korean economy.

Commerce has conducted some assessments of the prospective impacts  of sanctions, according to Commerce officials. According to Commerce  officials, the Under Secretary or Deputy Under Secretary communicates  requests for analyses of sanctions that originate with the NSC’s Principals  Coordinating Committee. According to Commerce officials, these  requests are infrequent, with very few received in recent years, and  generally related only to Russia and Iran.

According to Commerce, the results of these assessments may include  two components: (1) a simulation of potential economic impact and (2)  background data on trade flows and vulnerabilities. The first component  may include a projection of sanctions’ impact on gross domestic product  (GDP), consumer prices, production in specific industries, jobs, and trade  flows. The second component may include background on the amount  and nature of any U.S. trade with countries that might be sanctioned. For  example, in March 2015, Commerce produced an analysis to determine  the areas of greatest interdependence among the United States, Russia,  and U.S. partners that were at risk of being affected by prospective  sanctions against Russia.

Other Intelligence Agencies’ Assessments

Treasury and State officials reported using assessments of sanctions’  impacts provided by intelligence agencies outside Treasury or State.

Assessments used by Treasury. OFAC officials reported requesting  assessments from other intelligence agencies, in addition to OIA’s  assessments. According to OFAC, the type of assessment  requested—for example, gauging the reaction of a target or  government leadership to sanctions or examining a target’s assets  globally—depends on the issue and the program. OFAC also reported  requesting analysis of sanctions’ impact on strategic targets and their  associates. OFAC officials reported that these assessments are taken  into account as Treasury considers developing additional sanctions  policies, targets, or both.

Assessments used by State. INR and SPI officials stated that they  use assessments of sanctions’ impact conducted by intelligence  agencies outside State. According to an INR official, the INR  sanctions team will obtain Intelligence Community assessments  relevant to State policymakers concerns. SPI officials stated that most  of the assessments they use are focused on the potential impact of  proposed sanctions. According to the officials, the assessments help  them design sanctions tools and develop targets to maximize impact.  For example, according to SPI officials, the Intelligence Community  will assess where the largest impact might be by assessing whether  actors are likely to cease particular activities if targeted or will identify  points where targets interface with the U.S. financial system. SPI  officials stated that the number of assessments conducted depends  on multiple variables, including current events in the targeted country  and the degree of senior policymaker interest. An INR official stated  that most Intelligence Community resources (i.e., intelligence  collection and analysis) are focused on just a few sanctions regimes,  such as North Korea, Iran, and Russia. Moreover, according to State  officials, routine, finished analysis—assessing the impact of sanctions  either before or after their imposition—is not always available from the  Intelligence Community or is slow in delivery. State officials stated that  this type of regular intelligence reporting and analysis is critical to  informing sanctions policymaking at all stages (e.g., planning,  targeting, implementing, enforcing, and revising).

Agencies Have Cited Difficulties in Conducting Assessments of Sanctions’ Effectiveness in Meeting Policy Goals

Treasury, State, and Commerce officials identified a range of analytic  issues that make it difficult to assess the effectiveness of a sanctions  program in meeting broad U.S. foreign policy goals. The difficulties they  cited included the following:  Isolating sanctions’ effects from other factors is difficult. Agency  officials cited the difficulty—or, in some cases, the impossibility—of  identifying sanctions as the sole or most significant cause of a target’s  action relative to U.S. policy goals. For example, a sanctioned country  may decide to cease certain behavior for any number of reasons that  may be unrelated to the sanctions or other U.S. policy measures.  OFAC officials also stated that behavioral change can be subtle,  incremental, and lacking clear correlations with specific causes. In  addition, Treasury officials noted that sanctions are often used in  conjunction with other policy tools, such as diplomatic engagement  with the target, export controls, and visa bans. Distinguishing the  impact of each policy tool used is exceedingly difficult due to the  limited information available via intelligence and law enforcement  channels, according to Treasury officials.

Policy goals and objectives often shift. Treasury officials stated  that U.S. policy goals and objectives underpinning the sanctions can  change over the course of a sanctions program, making it difficult to  measure sanctions’ effectiveness in achieving any ultimate policy  objective. According to OFAC officials, because sanctions programs  are ongoing, any assessments of a sanctions program’s effectiveness  would necessarily be interim, not final, and the metrics used to  measure effectiveness might change over the program’s duration.

Reliable data are sometimes lacking. Agency officials stated that a  lack of reliable data on certain targets or countries can also make it  difficult to assess the effectiveness of sanctions.

According to Treasury, State, and Commerce officials, given these  difficulties and limited resources, they do not conduct their own  assessments of the overall effectiveness of existing sanctions programs  in achieving broad policy goals. Instead, they have directed resources  toward the assessments of sanctions’ impacts on targets, such as the  impact on a target country’s economy or trade. Agency officials also  noted that there is no policy or requirement for agencies to assess the  effectiveness of sanctions programs in achieving broad policy goals.  However, Treasury and State officials stated that sanctions policy is  continuously evaluated informally by those implementing the sanctions,  as new information comes in and as new targets are developed.  Moreover, Treasury, State, and Commerce stated that agency  assessments of sanctions’ impacts often contribute to broader  interagency discussions, typically coordinated through the NSC, that  examine the effectiveness of sanctions in achieving broad policy goals.

According to agency officials, an NSC-led process allows the U.S.  government to draw on multiple agencies’ inputs and perspectives, and to  consider these issues in the larger policy context, given that sanctions are  often only one element of broader government-wide strategies to achieve  U.S. policy goals.

Studies Suggest Certain Factors Contributed to More- Effective Sanctions, but These Studies May Not Fully Reflect Certain Types of U.S. Sanctions

We found strong evidence—based on studies examining factors that  contributed to the effectiveness of sanctions in changing targeted  countries’ behavior—that sanctions have been more effective when  implemented through an international organization, or when targeted  countries had some existing dependency on or relationship with the  United States. We also found strong evidence—based on studies  examining factors that increased the economic impact of sanctions on  targeted countries—that sanctions imposed through an international  organization were associated with greater impact. In addition, we found  strong evidence that the economic impact of sanctions has generally  been greater when they were more comprehensive in scope or severity.  Sanctions may also have unintended consequences for targeted  countries, such as negative impacts on human rights or public health. In  some studies, larger economic impacts were associated with more  unintended consequences, suggesting an important policy trade-off.  Some aspects of U.S. sanctions policy, such as targeted sanctions, were  generally not analyzed separately in the studies we reviewed, which could  reduce the studies’ applicability to contemporary policymaking.

Studies Suggest Sanctions Have Been More Effective When Implemented through an International Organization or When the Target Was Dependent on the United States

We found strong evidence, based on studies examining factors that  contributed to the effectiveness of sanctions in changing behavior, that  sanctions have been more effective when they were implemented through  an international organization (e.g., the United Nations) or when the target  had some existing dependency on or relationship with the United States  (e.g., U.S. foreign aid, military support or alliance, or relatively large  bilateral trade relationship). Studies using different methods, datasets,  and time periods consistently found that the United States was more likely  to achieve its sanctions goals when an international organization was  involved or when the target had some existing dependency on or  relationship with the United States.

We found some evidence, based on a smaller number of studies, that  sanctions have been more effective when the target state had low per- capita income, when a country’s threat of imposing sanctions was  assessed to be credible, or when sanctions imposed relatively high  costs on the target state. For example, one study found that the  likelihood of the target’s acquiescing to all of the sanctioning country’s  demands increased when sanctions were imposed on a target with low  per-capita income. Another study found that targets were more likely to  acquiesce in response to threatened sanctions when the United States  had not backed down against a resisting target recently. A third study  found that more-severe sanctions increased the likelihood that the  sanctioning country achieved more of its goals, suggesting that sanctions  imposing relatively high costs have been more effective.

Our review also suggests that in some circumstances, the risk of  sanctions has deterred states from undertaking activities that would likely  have resulted in the imposition of sanctions. Factors that have increased  the measured effectiveness of sanctions may also increase their deterrent  effect. For example, two studies found that the greater the trade flows  between the target state and the sanctioning country, the greater the  likelihood of sanctions’ success. A separate study demonstrated that  this same dependency—greater trade between the target and the United  States—led to greater deterrence of nuclear proliferation.

More generally, states are likely to consider the risks associated with  undertaking activities that could lead to the imposition of economic  sanctions, among other factors. These risks include the likelihood of  sanctions being imposed or removed, the states’ vulnerabilities to the  different types and amounts of pressure that could result from sanctions,  and the consequences that the states would experience if sanctions were  imposed. See the text box for more detail on the potential risks that states  that could be the target of sanctions might consider. (The text box is  intended to provide a more general framework for understanding how  states may anticipate and respond to sanctions; it reflects, but is not  limited to, the specific factors included in the studies we reviewed.)

Risk Framework for States That May Be Targets of Economic Sanctions  Likelihood of sanctions’ being imposed or removed. States that may be targets of  sanctions may assess the credibility of any explicit threats to impose or maintain  sanctions and the credibility of any assurances that sanctions will be removed when the  activity that motivated the imposition of sanctions ceases.   Vulnerabilities to potential pressure from sanctions. States that may be targets of  sanctions may assess whether the benefits of withstanding pressure that could result  from the sanctions exceed the costs. For example, states may be concerned that higher  economic costs from sanctions could be associated with greater impact on the material  wellbeing of individuals and firms. Higher economic costs could also make it more  difficult to compensate those affected by the sanctions—and those costs could be  especially burdensome in states with low per-capita income. However, states likely  consider not only the costs from sanctions but also the extent to which they might over  time avoid or adapt to these costs. For example, if potential sanctions are likely to  disrupt trade and investments from major commercial partners, states that are potential  targets may examine whether developing or expanding relationships with third parties  could mitigate the loss of these economic relationships. Sanctions imposed via an  international organization (e.g., a multilateral approach associated with the United  Nations) may make it more difficult for targets to avoid or adapt to sanctions—for  example, by finding alternative commercial partners—and may signal a more robust  international consensus regarding the objectives of the sanctions.   Consequences if sanctions are imposed. States that may be targets of sanctions  may assess the direct financial impact as well as future diplomatic, political, or security  implications of the potential sanctions. That is, before engaging in activities that could  trigger sanctions, states that depend on the United States may consider the possible  impact of their actions on their future relationships with the United States in other areas,  including military cooperation or the provision of aid. Conversely, states that are less  dependent on the United States might anticipate fewer ongoing benefits from  acquiescing to U.S. demands.

Research on the Effectiveness of Sanctions May Not Fully Reflect Certain Types of U.S. Sanctions

Two important types of U.S. sanctions—targeted sanctions and  secondary sanctions—were present during the time periods covered by  the studies we reviewed. However, the studies generally did not account  differently for these two sanctions types than for non-targeted and primary  sanctions, respectively. As a result, the studies generally did not reflect  differences between the effectiveness of these types of sanctions. This  limitation of the available studies could reduce the applicability of this  research to contemporary policymaking.

Targeted sanctions. Targeted sanctions restrict transactions of and  with specific entities and individuals, such as those who may have  influence with a state’s government. In response to such sanctions,  the targeted actors may in turn influence their government to change  its behavior. Targeted sanctions seek to minimize impact on society at  large and maintain most trade relationships with non-targeted actors  in the country. However, our interpretation of studies of sanctions  suggests that the targeted actors may use their influence with their  government to extract concessions that compensate them for the  impact of sanctions, which could limit the effectiveness of certain  targeted sanctions.

Secondary sanctions. Secondary sanctions, also known as  supplementary sanctions, target third-party actors doing business  with, supporting, or facilitating targeted regimes, persons, and  organizations. From the perspective of a third-party actor, secondary  sanctions likely increase the risk involved in commercially partnering  with primary sanctions targets. Thus, secondary sanctions, especially  those implemented by a country as large and interconnected as the  United States, may make it more difficult for primary targets to avoid  or adapt to sanctions. Our interpretation of studies of sanctions  suggests that the effects of secondary sanctions imposed by the  United States could be similar to the effects of sanctions imposed with  a large or multilateral coalition through an international organization,  since sanctions imposed through an international organization also  increase the difficulty of finding alternative commercial partners.  However, our interpretation of the studies suggests that if secondary  sanctions were imposed without an international organization they  would be unlikely to signal a robust international consensus regarding  the sanctions’ objectives, and thus may not as effectively deter their  targets, or third parties, from developing alternative commercial  arrangements.

While the studies we reviewed generally did not separately analyze  targeted or secondary sanctions, states remain likely to consider the risks  associated with undertaking activities that could lead to the imposition of  these sanctions and sanctions in general. With respect to targeted and  secondary sanctions, states—both primary targets and third-country  actors—are likely to consider, among other things, the risks associated  with undertaking activities that could result in targeted or secondary  sanctions and the consequences they would experience if targeted or  secondary sanctions were imposed.

Studies Suggest Comprehensive Sanctions Have Had Larger Economic Impacts but Could Also Yield More Unintended Consequences

We found strong evidence, based on studies examining factors that  increased the economic impact of sanctions, that sanctions’ economic  impacts on targets have generally been greater when the sanctions were  more comprehensive or were imposed through an international  organization. For example, one study found that UN sanctions had an  adverse impact on target countries’ economic growth and that this impact  increased with more-comprehensive sanctions. Another study found  that imposing sanctions along with other countries led to reductions in  both U.S. and other Group of Seven countries’ bilateral trade with  targeted countries.

Some other studies suggest that sanctions may also have unintended  consequences. For example, some studies suggest that sanctions have  had a negative impact on human rights, the status of women, public  health, or democratic freedoms in target countries. In addition, more  frequent and comprehensive use of sanctions could encourage sanctions  targets, potential targets, and their commercial partners to develop trade  and financial ties that are less dependent on the United States.

The extent of these unintended consequences can be proportionate to  the comprehensiveness or economic impact of sanctions. As a result, the  cost or comprehensiveness of sanctions could entail important policy  trade-offs—that is, higher economic costs may be more coercive but may  also yield greater unintended consequences. For example, two academic  studies, based on data from sanctions implemented between 1972 and  2000, found that the negative impact of sanctions on democratic and  press freedoms was generally greater with more comprehensive  sanctions. Two other studies found that the public health effect of  sanctions depended on the costliness or economic impact of the  sanctions. Targeted sanctions could, in principle, reduce the unintended  consequences of sanctions by reducing economic impacts on society at  large.

We provided a draft of this report to Treasury, State, and Commerce for  review and comment. We received technical comments from all three  agencies, which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of the Treasury, the Secretary of State, the  Secretary of Commerce, and other interested parties. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-8612, or GianopoulosK@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix III.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to (1) describe how the roles of the Departments of  the Treasury (Treasury), State (State), and Commerce (Commerce) in  implementing U.S. sanctions authorities are identified; (2) examine the  extent to which U.S. agencies assess the effectiveness of sanctions; and  (3) identify factors that have been shown by publicly available studies to  contribute to the effectiveness of economic sanctions.

To describe how Treasury’s, State’s, and Commerce’s roles in  implementing U.S. sanctions authorities are identified, we reviewed legal  authorities, including statutes and executive orders, that authorize various  sanctions programs and interviewed relevant agency officials. We also  discussed with Treasury, State, and Commerce officials the interagency  process used in determining sanctions roles.

To examine the extent to which U.S. agencies assess the effectiveness of  sanctions, we interviewed officials and reviewed documents from  Treasury, State, Commerce, and the Office of the Director of National  Intelligence. We also obtained and reviewed agency assessments for  sanctions programs related to Burundi, North Korea, Russia, and  Somalia. We selected these country-based sanctions programs to obtain  at least one country program with more than 200 current sanctions  designations and at least one country program with fewer than 200 but  more than 10 current sanctions designations as of September 2018. In  addition, we included a mixture of different-size economies, based on  annual gross domestic product (GDP). We used the agencies’  assessments of the selected programs to gain insight into the types of  analysis conducted.

To identify factors that have been shown by publicly available studies to  contribute to the effectiveness of economic sanctions, we conducted a  literature search for studies that examined:  factors that contributed to the effectiveness of economic sanctions in  changing behavior, and  factors that increased the economic impact of sanctions.

To identify existing studies, we used three methods. First, we conducted  searches of various databases, which produced 280 studies. Second, we  conducted snowball sampling, by identifying additional studies cited in  papers we had already identified. Third, we asked several academic  experts to validate our list of studies and recommend any additional  studies that they felt met our criteria.

To focus on recent research on the factors that contributed to the  effectiveness or economic impact of economic sanctions and to target  articles for detailed review, we included studies that met the following  criteria:

The study evaluated the factors that contributed to the effectiveness  or economic impact of sanctions.

The study included quantitative analysis of research data, which  aggregated and identified patterns across many sanctions episodes.

The study was published in a peer-reviewed journal or was an  academic working paper.

The study included data on U.S.-imposed bilateral or multilateral  sanctions but may also have included sanctions imposed by other  countries.

The study was published from 2004 through October 2018. As an  additional date restriction, we only included studies with at least some  data from 2000 through October 2018, though the study could have  included earlier data as well, in order to improve the likely relevance  of the research. The publication date restriction made it more likely  that included studies would be cognizant of an important source of  bias in earlier sanctions research. Prior to 2004, researchers tended  to examine the impact of implemented sanctions and generally  excluded cases where the threat of sanctions might have led a target  to change their behavior prior to implementation. More generally,  observed outcomes of implemented economic sanctions are not  representative of the range of circumstances in which sanctions could  be imposed, threatened, or useful for deterrence, and as a result  these observed outcomes tend to understate the effectiveness of  economic sanctions.

Finally, to select the studies to be included in our in-depth review, we  evaluated them to determine whether they met additional criteria for  methodological soundness. We assessed whether the studies used and  clearly described appropriate statistical methods to adjust, or control, for  factors that could influence the effectiveness or economic impact of  sanctions. Additionally, we included only papers that ascribed statistical  precision to modeled estimates.

To validate the studies we selected for in-depth review, we requested  suggestions regarding our list of studies from the following academic  experts: Daniel W. Drezner, Bryan R. Early, and T. Clifton Morgan. We  identified these researchers on the basis of the relevance of their  publications to our objectives, the methodological impact of their  contributions to the literature, and the number of citations of any relevant  publications since 2009.

Applying the selection criteria and the criteria for methodological  soundness and incorporating the academic experts’ suggestions resulted  in a list of 17 sufficiently rigorous studies, all of which had appeared in  peer-reviewed journals. Ten studies were relevant to the factors that  contributed to the effectiveness of economic sanctions and seven studies  were relevant to the factors that increased the economic impact of  sanctions.

To obtain relevant context and background, we also examined additional  studies related to the factors that contributed to the effectiveness of  economic sanctions. These studies did not meet our criteria for inclusion  in our in-depth review but provided insight into issues related to the  analysis of effectiveness of sanctions and potential unintended  consequences of sanctions. All of the studies that met the criteria for our  in-depth review, as well as others we cited, are included in appendix II.

To review the 17 studies we selected, we used a data collection  instrument (DCI) designed to record each study’s research methodology,  including its data, outcome measures, control variables, limitations, and  analytic techniques and to summarize its major findings. Analysts then  independently reviewed the studies and the information captured in the  DCIs, reconciling any differences in their assessments through  discussion. Next, we summarized the findings and categorized and  aggregated the factors relevant to the effectiveness or economic impact  of sanctions. We also shared a summary of our initial findings with the  academic experts, who generally concurred with our findings.

We characterized factors as being supported by “strong evidence” for the  purposes of our review only if at least four studies—including more than  half of studies that included this factor—found it to have a statistically  significant effect and no studies found a statistically significant effect with  the opposite sign. We characterized factors as being supported by “some  evidence” for the purposes of our review only if at least two studies— including at least half of studies that included this factor—found it to have  a statistically significant effect and no studies found a statistically  significant effect with the opposite sign.

The studies we examined varied in the quality of their methodologies, and  as a result, we could not confidently report on precise estimates of the  impact of different factors on the effectiveness or economic impact of  sanctions. While the statistical models used in the studies we reviewed  controlled for factors that could influence the success or failure of  sanctions in different circumstances, these models are also subject to  some biases and imperfections. For example, studies may not have  accounted for all factors that might influence the success of sanctions or  may not have recognized or controlled for selection biases that influenced  when and how sanctions were imposed. Finally, sanctions datasets  include variables for which researchers exercised varying degrees of  judgment to code accurately and consistently and which therefore may be  measured with imprecision or error.

Appendix II: Publicly Available Studies Reviewed

Bapat, Navin A., Tobias Heinrich, Yoshiharu Kobayashi, and T. Clifton  Morgan. “Determinants of Sanctions Effectiveness: Sensitivity Analysis  Using New Data.” International Interactions, vol. 39, no. 1 (2013): pp. 79- 98.

Bapat, Navin A., and T. Cliff Morgan. “Multilateral Versus Unilateral  Sanctions Reconsidered: A Test Using New Data.” International Studies  Quarterly, vol. 53, no. 4 (2009): pp. 1075-1094.

Biglaiser, Glen, and David Lektzian. “The Effect of Sanctions on U.S.  Foreign Direct Investment.” International Organization, vol. 65, no. 3  (2011): pp. 531-551.

Caruso, Raul. “The Impact of International Economic Sanctions on Trade:  Empirical Evidence over the Period 1960-2000.” Rivista Internazionale di  Scienze Sociali, vol. 113, no. 1 (2005): pp. 41-66.

Early, Bryan R. “Unmasking the Black Knights: Sanctions Busters and  Their Effects on the Success of Economic Sanctions.” Foreign Policy  Analysis, vol. 7, no. 4 (2011): pp. 381-402.

Early, Brian R., and Robert Spice. “Economic Sanctions, International  Institutions, and Sanctions Busters: When Does Institutionalized  Cooperation Help Sanctioning Efforts?” Foreign Policy Analysis, vol. 11,  no. 3 (2015) pp. 339-360.

Hatipoglu, Emre, and Dursun Peksen. “Economic Sanctions and Banking  Crises in Target Economies.” Defence and Peace Economics, vol. 29, no.  2 (2018): pp. 171-189.

Krustev, Valentin L., and T. Clifton Morgan. “Ending Economic Coercion:  Domestic Politics and International Bargaining.” Conflict Management and  Peace Science, vol. 28, no. 4 (2011): pp. 351-376.

Lektzian, David, and Dennis Patterson. “Political Cleavages and  Economic Sanctions: The Economic and Political Winners and Losers of  Sanctions.” International Studies Quarterly, vol. 59, no. 1 (2015): 46-58.

Major, Solomon. “Timing Is Everything: Economic Sanctions, Regime  Type, and Domestic Instability.” International Interactions, vol. 38, no. 1  (2012): pp. 79-110  Miller, Nicholas L. “The Secret Success of Nonproliferation Sanctions.”  International Organization, vol. 68, no. 4 (2014): pp. 913-944.

Neuenkirch, Matthias, and Neumeier, Florian. “The Impact of UN and US  Economic Sanctions on GDP Growth.” European Journal of Political  Economy, vol. 40, part A, (2015): pp. 110-125.

Nooruddin, Irfan, and Autumn Lockwood Payton. “Dynamics of Influence  in International Politics: The ICC, BIAs, and Economic Sanctions.” Journal  of Peace Research, vol. 47, no. 6 (2010): pp. 711–721.

Peksen, Dursun. “Autocracies and Economic Sanctions: The Divergent  Impact of Authoritarian Regime Type on Sanctions Success.” Defence  and Peace Economics, Vol. 30, No. 3 (2017): pp. 253-268.

Peksen, Dursun and Byunghwan Son. “Economic Coercion and Currency  Crises in Target Countries.” Journal of Peace Research, vol. 52, no. 4  (2015): pp. 448-462.

Peterson, Timothy M. “Sending a Message: The Reputation Effect of US  Sanction Threat Behavior.” International Studies Quarterly, vol. 57, no. 4  (2013): pp. 672-682.

Shin, Geiguen, Seung-Whan Choi, and Shali Luo. “Do Economic  Sanctions Impair Target Economies?” International Political Science  Review, vol. 37, no. 4 (2016): pp. 485-499.

Allen, Susan Hannah, and David J. Lekztian. “Economic Sanctions: A  Blunt Instrument?” Journal of Peace Research, vol. 50, no. 1 (2013): pp.  121-135.

Drezner, Daniel W. “Sanctions Sometimes Smart: Targeted Sanctions in  Theory and Practice.” International Studies Review, vol. 13, no. 1 (2011):  pp. 96-108.

Drezner, Daniel W. “The Hidden Hand of Economic Coercion.”  International Organization, vol. 57, no. 3 (2003): pp. 643-659.

Drury, A. Cooper, and Dursun Peksen. “Women and Economic Statecraft:  The Negative Impact Economic Sanctions Visit on Women.” European  Journal of International Relations, vol. 20, no. 2 (2014): pp. 463-490.

Forrer, John. “Economic Sanctions: Sharpening a Vital Foreign Policy  Tool.” Atlantic Council Issue Brief. Washington, D.C.: Atlantic Council,  June 2017.

Harrell, Peter. “Is the U.S. Using Sanctions Too Aggressively? The Steps  Washington Can Take to Guard Against Overuse.” Foreign Affairs.  September 11, 2018.

Licht, Amanda A. “Hazards or Hassles: The Effect of Sanctions on Leader  Survival.” Political Science Research and Methods, vol. 5, no.1 (2017):  pp. 143-161.

Marinov, Nikolay. “Do Economic Sanctions Destabilize Country Leaders?”  American Journal of Political Science, vol. 49, no. 3 (2005): pp. 564-576.

Peksen, Dursun. “Coercive Diplomacy and Press Freedom: An Empirical  Assessment of the Impact of Economic Sanctions on Media Openness.”  International Political Science Review, vol. 31, no. 4 (2010): pp. 449-469.

Peksen, Dursun. “Economic Sanctions and Human Security: The Public  Health Effect of Economic Sanctions.” Foreign Policy Analysis, vol. 7, no.  3 (2011): pp. 237-251.

Peksen, Dursun, and A. Cooper Drury. “Coercive or Corrosive: The  Negative Impact of Economic Sanctions on Democracy.” International  Interactions, vol.36, no. 3 (2010): pp. 240-264.

Wood, Reed M. “‘A Hand upon the Throat of the Nation’: Economic  Sanctions and State Repression, 1976–2001.” International Studies  Quarterly, vol. 52, no. 3 (2008): pp. 489-513.

Appendix III: GAO Contact and Staff Acknowledgements

In addition to the contact named above, Drew Lindsey (Assistant  Director), Michael Maslowski (Analyst in Charge), Eugene Beye, Nisha  Rai, Michael Hoffman, Reid Lowe, Christopher Keblitis, Grace Lui, Justin  Fisher, Leia Dickerson, Michael Simon, and Julia Robertson made key  contributions to this report.

When foreign countries engage in activities that threaten U.S. interests, the U.S. government can impose economic sanctions. For example, the United States may prohibit certain exports or freeze a foreign entity’s U.S. assets to try to stop weapons proliferation or human rights abuses.

The Departments of State, Commerce, and the Treasury have assessed sanctions’ impacts—for example, on a targeted country’s economy or trade. But they haven’t determined whether sanctions really work—nor are the agencies required to do so.

Academic studies show sanctions are more effective when they’re implemented through an international organization like the UN.