Belarus ahead of Russia in the number of objects of US sanctions under Biden

In some sanctions programs, the status of SDN can be even tougher in terms of restrictions, when the threat of secondary sanctions against persons and companies from third countries for cooperation with SDN is added to direct restrictions in US jurisdiction. In sanctions against Russia, this dimension appeared in 2017 with the adoption of the CAATSA law. It pursues the goal of virtually global isolation of persons under US sanctions.

If we talk about the data for the last decade, then Russia is second only to Iran in the number of American sanctions decisions, noted CNAS experts a year ago. However, such an analysis does not take into account the different significance of sanctions targets: blocking, for example, the business of such billionaires as Oleg Deripaska or Viktor Vekselberg, can create a much greater effect than sanctions against dozens of less significant objects. Since the end of 2021, the United States has been discussing tough sanctions against Russia (in particular, against the largest banks) in the event of a “military escalation” in the Ukrainian direction.

The CNAS analysis is also incomplete because it does not reflect sectoral sanctions, such as Biden’s April 2021 ban on U.S. investors from participating in primary placements of Russian federal loan bonds (OFZs). Changes in the sanctions policy, such as the resumption of sanctions against nine Belarusian state-owned enterprises in June, are also not taken into account: formally, they were already on the SDN list, but the US authorities canceled the license that allowed transactions with these sub-sanctioned organizations.

Throughout 2021, the Biden administration conducted a review of the sanctions policy and completed it in October. One of the conclusions revision has become a reliance on a multilateral approach (where possible), when the United States coordinates its sanctions decisions with allied states. Under Trump, the U.S. has more often gone it alone in confrontations with Europe, especially in the U.S. “maximum pressure” campaign on Iran, when secondary sanctions over economic relations with Tehran began to threaten European companies. Under Biden, the US has been negotiating with Iran to revive a 2015 multilateral deal to limit the country’s nuclear program (the US withdrew from it in 2018 under Trump).

Another conclusion of the Biden team is that sanctions must be carefully calibrated to avoid unforeseen economic and humanitarian consequences for the US itself and Western countries. For comparison, during the Trump presidency, an episode of sanctions against Deripaska’s aluminum company Rusal became possible, due to which world aluminum prices jumped and caused problems for Rusal’s European enterprises. Less than a year later, sanctions against the company were lifted, although for this the United States demanded that Deripaska leave the controlling shareholders.

As for China, although the Biden administration lifted some of the sanctions against Chinese companies imposed under Trump, it generally continued the policy of economic restrictions. In particular, in 2021, the US Treasury imposed sanctions on Chinese officials, whom it considered undermining democracy in Hong Kong.

Other features of the sanctions in the first year of Biden were a significant number of people added to the SDN list under the thematic GLOMAG sanctions program (for human rights violations in the world, according to the global Magnitsky law) – 173, of which 67 were in Bulgaria (for corruption surrounding parliamentary elections in November), as well as the first of its kind sanctionsrelated to virtual currency: against the Suex cryptocurrency exchange (registered in Prague, but operating in Russia).