Sanctions by the Numbers: U.S. Sanctions Designations and Delistings, 2009–2019

Sanctions by Category

The U.S. government groups sanctions designations and delistings into four categories: individuals, entities, vessels, and aircrafts. While trends in designations and delistings have changed over time, the relative proportion of each category notably has stayed similar.

Designations by Category by Year, 2009–2019

Delistings by Category by Year, 2009–2019

Sanctions Designations by Program

The number of sanctions programs has increased to cover new issues and target new countries, behaviors, and even types of transactions. While only half of the sanctions programs used in 2009 were used in 2019, they account for the largest share of enacted sanctions.

Sanctions Programs in 2009 and 2019

Note:
Burma includes all entities sanctioned pursuant to Executive Orders 13619 and 13651.

Counternarcotics includes all entities sanctioned pursuant to EO 12978 and the Foreign Narcotics Kingpin Designation Act.

North Korea includes all entities sanctioned pursuant to EOs 13687, 13722, and 13810.

Nicaragua includes all entities sanctioned pursuant to EO13851 and the Nicaragua Human Rights and Anticorruption act of 2018.

Iran includes all entities sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, the Iran Human Rights and Hostage-Taking Accountability Act, the Iran Threat Reduction and Syria Human Rights Act, as well as EOs 13553, 13608, 13846, and 13876.

Ukraine includes all entities sanctioned pursuant to EOs 13660, 13661, 13685.

Russia/SSI includes all entities identified pursuant to EO 13662.

Magnitsky includes all entities sanctioned pursuant to the Sergei Magnitsky Rule of Law Accountability Act of 2012 and the Global Magnitsky Human Rights Accountability Act.

Venezuela includes all entities sanctioned pursuant to EOs 13692, 13850, and 13884.

Methodology

Regarding the methodology used for this effort to examine sanctions by the numbers, the author and reviewers acknowledge the difficulty in assessing the use of sanctions while avoiding statistical distortions. In an effort to reduce misconstruction, we count a designated entity as designated once, at the time of its first inclusion in any sanctions program, regardless of the number of programs it falls under at the time of the initial designation. Additionally, we count a named entity only once even if it has multiple subsidiaries or vessels. We track all sanctions authorities used at the time of designation, and, when evaluating the use of these programs, include all programs in the tally. Conversely, we count delistings only when all sanctions designations under every authority are removed and the entity is no longer on the sanctions list. We think this allows for the most accurate comparison across programs, years, and presidencies.

The author would like to thank Neil Bhatiya, Peter Harrell, Elizabeth Rosenberg, and Adam Smith for their review of this project, as well as Maura McCarthy, Melody Cook, and Loren DeJonge Schulman for their assistance with the production of this project.

Learn More

The CNAS Sanctions by the Numbers series offers comprehensive analysis and graphical visualization of major patterns, changes, and developments in U.S. sanctions policy and economic statecraft. Members of the CNAS Energy, Economics, and Security Program collect and analyze data from publicly available government sources, such as the Treasury Department’s Office of Foreign Assets Control.