US Officials Sometimes Unable to Tell Whether Sanctions Are Effective, GAO Report Says

Sanctions officials are sometimes unable to judge the effectiveness of the Trump administration's sanctions regimes, the Government Accountability Office said, pointing to the difficulty of tracing the effects of sanctions and the administration's constantly changing foreign policy goals. Officials said it is sometimes impossible to determine whether U.S. sanctions are the only or even the “most significant” reason for a foreign country changing its behavior, the report said. They also said U.S. policy goals can change while a sanctions regime is still active, “making it difficult to measure sanctions’ effectiveness in achieving any ultimate policy objective.”

The report, released Oct. 3, pulls from documents and interviews with officials from the Treasury, State and Commerce departments as well as the intelligence community. It also follows criticism from sanctions experts and former government officials who called the U.S.’s sanctions regimes ineffective (see 1909300054), confusing (see 1908010020) and troubling (see 1904300226).

U.S. officials told the GAO that countries may stop or continue certain activities “for any number of reasons” unrelated to sanctions, making it a near “impossibility” to track whether U.S. pressure is meeting foreign policy goals. And even when countries do change behavior, the change can be “subtle, incremental, and lacking clear correlations with specific causes,” the report said, and could be confused with the impacts of other foreign policy tools, such as export controls. “Distinguishing the impact of each policy tool used is exceedingly difficult due to the limited information available via intelligence and law enforcement channels,” the GAO said, citing Treasury officials.

While U.S. policy goals often change during a sanctions regime, the “ongoing” nature of sanctions programs make any assessments of the programs “interim, not final,” the report said. Metrics used to measure the effectiveness of a sanctions program may change, the GAO said, and “a lack of reliable data on certain targets or countries can also make it difficult” to determine the effectiveness.

Even so, Commerce, State and the Treasury are not required to assess whether their sanctions regimes are achieving broad policy goals, officials told the GAO. Instead, they measure sanctions’ impacts on specific targets, such as a country’s economy and trade sector, according to the report. Sanctions policy is evaluated “informally by those implementing the sanctions” and by the National Security Council, the officials said.

The GAO also examined the instances when U.S. sanctions are most effective, saying they work best when implemented through an international organization or when the targets depend on the U.S. When sanctions are imposed by an organization such as the United Nations, or when they are “more comprehensive in scope or severity,” they tend to have “greater impact,” the report said.

“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,” the report said.

The GAO also found that certain factors make sanctions much more likely to work than others. When there is a large trade flow between the target state and the sanctioning country, there is a greater “likelihood of sanctions’ success. A target is also more likely to agree to the sanctioning country’s demands if it is a target with a low per-capita income, the report said.

In some cases, secondary sanctions can be just as effective as multilateral sanctions imposed by an international organization, the GAO said. Secondary sanctions “make it more difficult for primary targets to avoid or adapt to sanctions” and “increase the difficulty of finding alternative commercial partners,” the report said. But when secondary sanctions are imposed unilaterally, they are “unlikely to signal a robust international consensus regarding the sanctions’ objectives, and thus may not as effectively deter their targets.”