Sanctions by the Numbers: 2023 Year in Review

The major takeaway of 2023 is the sheer number of financial sanctions levied by the United States, highlighting the intensifying reliance on sanctions as a key foreign policy tool. With 11 sanctions programs receiving over 20 designations, certain foreign policy areas are more prominent, indicating their prioritization by the Biden administration.

Country-Specific Financial Sanctions

The U.S. government utilizes country-specific sanctions regimes to target certain activities undertaken by governments and related actors that are counter to U.S. foreign policy and national security objectives. Most SDN designations tend to fall under country-specific sanctions regimes, with 77 percent of 2023 designations issued under at least one country program. In 2023, the U.S. government targeted 14 states with country-specific sanctions, an increase from 9 in 2022. The top five sanctioned countries in 2023 were Russia, Iran, Belarus, Burma, and the Democratic People’s Republic of Korea (DPRK or North Korea). The top 10 countries sanctioned in 2023 have remained the highest sanctioned countries over the last 10 years and have not seen high rates of delistings. These countries’ persistent presence on the SDN list indicates that many of these actors have not changed their behavior despite years of increasing sanctions levied across various sectors.

This graph shows the country in which sanctioned individuals hold nationality and in which sanctioned entities are registered or hold financial accounts. It is program agnostic; the sanctioned persons located in these countries could have been listed under any country-specific or thematic program. Russia hosts the highest number of sanctioned individuals and entities, at 1,227 persons. Three countries host over 100 sanctioned persons: Mexico (148 designations), China (145 designations), and Iran (141 designations). Other major locations include the United Arab Emirates (92 designations), Cyprus (66 designations), Lebanon (51 designations), Maldives (50 designations), Turkey (50 designations), Belarus (43 designations), Burma (29 designations), Germany (27 designations), North Korea (24 designations), and Somalia (23 designations).

Russia

Russia-related sanctions, totaling 1,522 SDN designations, vastly surpassed any other sanctions category in 2023, a development that has persisted since Russia’s invasion of Ukraine in February 2022. Russia-related designations accounted for 61 percent of all 2023 designations, a slight decrease from 75 percent in 2022. The volume of designations indicates the United States’ resolve to inflict sustained economic pressure on Russia, including through targeting sanctions evasion and creating novel mechanisms such as the oil price cap. The United States, often in coordination with allies and partners, issued sanctions monthly throughout 2023—sometimes designating hundreds of persons at once—primarily targeting entities, individuals, and networks tied to Russia’s military-industrial complex, financial institutions, and energy sector. In 2023, Russia sanctions also targeted human rights abuse and corruption, election interference, occupation of Ukraine, and evasion of the oil price cap.

In February 2023, the United States announced that its sanctions strategy was to “methodically and intensively target sanctions evasion efforts around the globe, close down key backfilling channels, expose facilitators and enablers, and limit Russia’s access to revenue needed to wage its brutal war in Ukraine.” Correspondingly, most sanctioned entities were designated due to their support of Russian efforts to circumvent or evade sanctions and other economic measures, access critical technology procurement networks, and facilitate illicit financial activities. Policymakers targeted these sectors because Russia cannot produce a substantial amount of the equipment, technology, and other materials it needs to sustain its invasion. Russia has since offshored much of the production necessary to maintain its military-industrial complex, and now depends on third-country suppliers.

Secondary Sanctions

To augment these efforts, in December the Biden administration amended Executive Order (EO) 14024—which authorized sanctions on Russia’s military-industrial base—by issuing Executive Order 14114 authorizing sanctions on foreign financial institutions involved in helping Russia evade existing financial restrictions. The sanctions represent the first major effort to employ secondary sanctions against third-party persons assisting Russia since the 2022 invasion of Ukraine. Although the United States’ use of secondary sanctions has previously caused tensions with allies due to their extraterritorial nature, the United States and its allies are increasingly aligned on the need to use such measures to stem sanctions evasion routes in third-party markets. The EO also allows for the United States to prohibit import of Russian-origin items that have been processed or substantially transformed in third countries, including Russian seafood and diamond products.

Several sanctioned networks, facilitators, and their businesses operate in third countries—touching 55 countries in total—and enable Russian critical technology procurement and illicit financial activity. Roughly 20 percent of 2023 Russia-related designations targeted persons outside of Russia, with the highest number of those designated located in Cyprus (57 designations), the United Arab Emirates (42 designations), China (38 designations), and Turkey (28 designations). Russian President Vladimir Putin has been fostering economic relationships with leaders in Beijing, Abu Dhabi, and Ankara, which have come to bear fruit over the last few years. Since the 2022 invasion of Ukraine, these countries have become hubs for exporting, reexporting, and transshipping foreign-made—including G7—technology and equipment to Russia. Although designations outside of Russia represent a small percentage of the total Russia-related designations, they indicate increasing diplomatic, financial, and military cooperation between Russia and these countries.

Energy, Mining, and Metals

The United States also escalated existing sanctions on the Russian energy, metals, and mining sectors—some of the Kremlin’s largest revenue generators—to include more entities connected to energy production and export, and increase the scope of sanctionable activities in the metals and mining sector. The United States further expanded the scope of energy sector sanctions in late 2023 by targeting entities involved in Russia’s future liquid natural gas production. The goal of these sanctions is to target Russia’s current and future revenue without triggering energy insecurity in nations that currently depend on Russian oil and gas. Significant 2023 sanctions in the energy sector also include those targeting entities and vessels that breached the oil price cap. In contrast, the European Union (EU) only marginally increased its 2023 sanctions targeting the Russian energy sector—originally issued in 2015 and then expanded in 2022—mainly by tightening enforcement of the G7 oil price cap and imposing a new ban on Russian liquified petroleum gas. The EU has been reluctant to target the Russian energy sector too severely, issuing sanctions on fewer entities and activities than the United States, partly due to its greater dependency on Russian liquified natural gas, pipeline gas, and oil. Some of the most significant sanctions coordination between the United States and the G7 in 2023 revolved around a joint commitment to reduce Russia’s revenues from the Russian metals and mining sectors, including diamond exports. For additional analysis on U.S. and EU sanctions on the Russian energy, metals, and mining sectors, see Sanctions by the Numbers: The Russian Energy Sector.

Human Rights

The United States also levied sanctions on Russian persons involved in corruption and human rights violations. In 2023, most of these designations targeted persons and activities connected to the Wagner Group, a private paramilitary company that has perpetrated documented human rights abuses in Ukraine, Central Africa, and elsewhere. The United States first targeted the Wagner Group in 2016, designating its now-deceased leader, Yevgeniy Prigozhin, under Executive Order 13661 for his support of the Russian government and its aggression toward Ukraine. While the United States has since continued to target Wagner, the 2023 designations represent an increased focus on limiting the group’s support for Russia’s war-fighting efforts and global reach. Significant actions include designating the Wagner Group as a transnational criminal organization; targeting companies affiliated with Wagner’s global network; sanctioning Malian officials supporting the Group; and adding persons that facilitated the targeting, abduction, and forced displacement of women and children. Additionally, like-minded countries including Canada, the European Union, and the United Kingdom (UK) sanctioned Wagner in January 2023.

Although Russia remained the most-targeted country in 2023, the United States also sustained focus on other country-specific policy priorities. The United States applied financial sanctions to 13 countries other than Russia, led by Iran, North Korea, Belarus, and Burma.

Iran

Iran was the second highest sanctioned country in 2023. The U.S. government imposed 221 designations under Iran-specific SDN programs, including those on foreign financial institutions that facilitate Iran’s arms trade, petroleum and petrochemical transactions, financial sponsorship of global terror organizations, sanctions evasion, and support for other illicit activities. Sanctions frequently targeted the Islamic Revolutionary Guard Corps (IRGC)—the elite wing of the Iranian armed forces that has a deep influence on Iran’s regional policy and that controls critical segments of Iran’s economy. The IRGC, designated by the United States as a terrorist organization in 2019, projects Iranian influence across the region by building up military capabilities and supporting proxies, including Hezbollah and Hamas. In 2023, the United States sanctioned the IRGC ballistic missile and unmanned aerial vehicle production programs. Several rounds of designations throughout the year reflected the United States’ ongoing investigations into Iran’s international procurement networks, aiming to disrupt the transfer of sensitive U.S.- and foreign-origin technologies to the IRGC.

Evasion Efforts

A large number of the designations, totaling 65 for the year, were levied under the legal framework of Executive Order 13846, which authorizes the reapplication of sanctions on non-U.S. persons engaged in trade and transactions with Iran after the discontinuation of the Iran nuclear deal in 2018. In 2023, many of these designations focused on Iran’s use of front companies and other evasion tactics both in Iran and in third-party countries, which increasingly include China, Russia, the United Arab Emirates, and Venezuela. Many of the sanctions targeted networks that allow the IRGC to buy and sell arms and military supplies and route aid to global terror syndicates through financial firms in China and Russia. These illicit procurement and financial networks expanded in 2023, with Russia purchasing aerial vehicles from Iran to use in its war against Ukraine, and Chinese banks forming a shadow banking network to help Iranian petroleum and petrochemical firms evade sanctions.

Human Rights

In addition to its focus on Iran’s evasion tactics, the United States also levied a large number of Iran-related sanctions, amounting to 49 designations, under the Iran Human Rights program, which targets IRGC members and other officials known or suspected of committing human rights abuses. The Biden administration sustained its efforts to support the nationwide protests in Iran that began in September 2022 following the death of Mahsa Amini. Several rounds of sanctions in 2023 targeted Iranian security officials involved in the ongoing brutal crackdown on peaceful demonstrations, political dissent, and free expression. On the anniversary of Amini’s death, the United States partnered with the United Kingdom, Canada, and Australia to sanction IRGC officials and intermediaries connected with violent suppression, censorship, and internet disruption related to the protest movement.

The United States levied the remaining Iran-related sanctions under the Iranian Transactions and Sanctions Regulations program (IRAN), the Iran Threat Reduction and Syria Human Rights Act of 2012 (IRAN-TRA), and the Conventional Arms program pursuant to Executive Order 13949 (IRAN-CON-ARMS-EO).

The Democratic People’s Republic of Korea

The United States continued to try to close the loop on DPRK sanctions evasion tactics, issuing 31 designations—roughly in line with the average number of sanctions designations issued over the last 10 years. Sanctions have consistently targeted activities related to DPRK’s weapons of mass destruction (WMD) program and largely align with United Nations sanctions. All 2023 U.S.-issued designations relate to nonproliferation financing and WMD development, with one designation related to North Korean support for Russian access to battlefield supplies and revenue generation. The United States used a variety of DPRK sanctions programs to designate individuals or entities outside of North Korea, including in Azerbaijan, China, the Democratic Republic of the Congo, Kazakhstan, Russia, Slovakia, and the United Kingdom. Over the years, DPRK’s sanctions evasion network has grown to span more of the globe, but U.S. government designations indicate that cooperation between China, DPRK, and Russia to support malign North Korean ambitions has been increasing since 2017. A high level of sanctions designations in 2016 and 2017 remain outliers—with the United States issuing 60 and 100 designations, respectively, due to accelerated advancement of the North Korean WMD program.

Belarus

Belarus was the third highest sanctioned country by the United States in 2023, receiving 44 designations under a sanctions program created by Executive Order 14038 in response to the fraudulent 2020 Belarusian presidential election. Over 90 percent of Belarus-related sanctions targeted Belarusian state-owned enterprises and government officials, escalating the U.S. response to the “ongoing brutal crackdown against the pro-democracy movement and civil society.” Persons targeted outside of Belarus under EO 14038 are located in Cyprus, Russia, Turkmenistan, and the United States (1 designation each), potentially signifying an expanding global sanctions evasion network. The U.S. government has continued to increase Belarus-related sanctions since 2020 and will likely continue to do so until Belarus successfully holds a free and fair presidential election.

Longtime Belarusian leader Alexander Lukashenko is a dependable ally of Vladimir Putin, especially since the 2022 invasion of Ukraine. Three entities located in Belarus were designated under Russian-related sanctions regimes—two joint stock companies and one private military company. The United States and Belarus have limited financial connectivity, which makes it difficult for U.S. sanctions to effectively restrict Belarusian external trade. Belarus imports nearly 60 percent of its goods from Russia and exports over 40 percent of its goods to Russia, a significant chunk of trade that is conducted in rubles and therefore outside the reach of dollar-based sanctions.

Burma

Burma, also known as Myanmar, stands out as the sole country among the highest sanctioned countries in 2023 that does not have significant economic ties to Russia. With a total of 33 SDN designations, Burma is the fifth highest sanctioned country in 2023. The Biden administration continued to target the military regime in Burma, which seized power via coup in 2021. The junta has continued to commit widespread and systematic human rights abuses, often targeting the Rohingya minority, almost all of whom live in state-imposed ghetto conditions or are displaced in neighboring Bangladesh. In 2023, the Biden administration climbed further up the sanctions escalation ladder, targeting not only military members involved in human rights abuses but also various military supply sectors. In March 2023, the United States sanctioned individuals and companies supplying the military with jet fuel used in air strikes against civilians. Subsequently, in June and August, the United States targeted government-controlled trade and investment banks facilitating foreign arms purchases. The United States then added to these sanctions by imposing restrictions on U.S. financing for Burma’s state-owned oil and gas company—its primary revenue source—in October 2023.

Although initial sanctions against Burma issued under Executive Order 14014 targeted the defense and financial sectors, the passage of the Burma Act of 2021, and its incorporation into the 2023 National Defense Authorization Act (NDAA), signified increasing U.S. resolve to support pro-democracy forces in Burma. The military regime in Burma has increasingly aligned with China in the absence of other international partners. China perceived the inclusion of Burma sanctions in the NDAA as a provocative intervention in its Indo-Pacific sphere of influence, prompting new engagement with Burma. The military regime is grappling with an internal crisis marked by weakened military authority and diminishing territorial control. Ethnic armed organizations and pro-democracy movements coordinated an unprecedented wave of attacks in October 2023, forcing the military to cede critical trade points and military posts. China recognizes that the military’s loss of control over significant territories will embolden already-expanding illicit trade circuits along Burma’s borders with China and Thailand, jeopardizing Chinese investments and border security.

Thematic Financial Sanctions

Thematic sanctions focus on transnational issues or actors engaged in illicit, malign, or nondemocratic activities. The Biden administration deployed seven thematic sanctions regimes in 2023, heavily targeting global terrorism (251 designations), illegal drug production and trafficking (192 designations), and WMD nonproliferation (100 designations). These three themes account for 82 percent of thematic sanctions designations in 2023, with the remaining listings targeting corruption and human rights violations (78 designations), malicious cyber-enabled activities (23 designations), transnational crime (13 designations), and hostage taking and the wrongful detention of U.S. citizens (5 designations).

Counterterrorism

Counterterrorism designations ranked highest among thematic sanctions regimes employed by the Biden administration for the second consecutive year. With 251 global terrorism–related designations, 2023 witnessed a slight increase from 2022, which saw 194 designations. In 2023, the Maldives, with 49 designations, claimed the top spot for global terrorism designations, which primarily targeted al-Qaeda and Islamic State of Iraq and Syria (ISIS) facilitators and financiers. Comparatively, Turkey led in global terrorism sanctions in 2022 with 38 designations, as the Biden administration targeted a Russian-backed sanctions evasion network that facilitated the sale of oil for the IRGC and diverted funds to Hezbollah. The United States continued its 2022 priority of targeting Hezbollah operatives and fundraisers in Lebanon, which ranked second in counterterrorism sanctions with 43 designations in 2023. Similarly, the Biden administration maintained financial pressure on al-Shabaab in Somalia, targeting 21 and 17 persons in 2023 and 2022, respectively. Generally, the Biden administration has consistently targeted the same terrorist groups and networks with sanctions—ISIS, al-Qaeda, and the IRGC and one of its main proxies, Hezbollah. This trend will likely continue into 2024 as these networks grow across Africa and the Middle East.

Following the October 7, 2023, Hamas attack on Israel, the Biden administration issued five rounds of designations on Hamas agents and financial facilitators across Algeria, Gaza, Sudan, Turkey, Qatar, and Iran. The United States initially targeted Hamas’s covert investment portfolio, including a Gaza-based cryptocurrency exchange used by Hamas to launder money and receive digital currency from international financiers. Hamas uses cryptocurrency as an alternative fundraising platform in order to crowdsource from anonymous supporters and evade U.S. and international financial sanctions. In November and December, Hamas-related sanctions expanded as the United States partnered with the United Kingdom to identify and designate Hamas officials, affiliates, and persons involved in Iran’s financial sponsorship of Hamas and Hezbollah, including a Lebanese money exchange. The United States also sanctioned networks funneling Iranian funding to Houthi rebels in Yemen. This action followed Houthi missile and drone attacks on Israel, threats against commercial shipping, and disruptions to maritime trade in the Red Sea. The Biden administration will likely continue to utilize sanctions as a tool to maintain regional stability as the war in Gaza continues and in any uncertain “day after” scenario.

Illicit Drugs

Drug trafficking–related sanctions surged from 2022 to 2023, with 46 and 192 designations, respectively. The Biden administration reshaped its drug trafficking sanctions framework in 2021 through Executive Order 14059, which created an Illicit Drugs sanctions program to replace the Narcotics Trafficking (SDNT) and Kingpin (SDNTK) sanctions programs. The new Illicit Drugs regime redirected focus from stimulants and opioids—originating from South America and the Middle East, respectively—toward the chemical inputs essential for synthetic opioids like methamphetamine and fentanyl, tied to China and Mexico. This adjustment aligns with the overall increase in drug-related designations, reflecting the growing network of actors funding, producing, and distributing synthetic drugs.

Shifts in the geographic distribution of sanctioned actors demonstrate the increasingly global nature of the drug trade. Consistent with 2022, Mexican persons remained the most sanctioned for illicit drugs in 2023, with individuals and entities located in Mexico receiving 19 designations in 2022 and 137 designations in 2023. In a departure from past trends, China emerged in 2023 with the second-highest number of sanctioned persons. Chinese persons, including pharmaceutical companies, received 44 designations for facilitating illicit narcotics production. This is a significant increase from zero illicit drug designations on Chinese persons in 2022 and five in 2021. Chinese entities and individuals are increasingly funding and facilitating precursor chemicals for opioid production by Mexican drug syndicates—most notably, the Sinaloa Cartel, Cartel Jalisco Nueva Generación, and Beltrán Leyva Cartel. In 2023, all 44 illicit drugs designations targeting Chinese nationals in connection to the drug trade were a result of cooperation with the Sinaloa or Jalisco cartels. Of the illicit drugs designations targeting Mexican individuals or entities in 2023, 65 were connected to Sinaloa, 54 were tied to Jalisco, and 17 were linked to Beltrán Leyva. President Biden addressed growing concerns about collaboration between Chinese industry and Mexican cartels at the Asia Pacific Economic Cooperation Summit in November 2023. On the sidelines of the forum, Biden and Chinese Communist Party General Secretary Xi Jinping reached a joint agreement to crack down on fentanyl production and resume bilateral cooperation on counternarcotics enforcement. Under this agreement, Xi pledged to curb the ability of Chinese chemical and pharmaceutical companies to export precursor materials and manufacturing hardware.

A notable surge in drug trafficking delistings marked a new development in 2023. The United States removed 352 individuals and entities previously sanctioned under the SDNT and SDNTK programs and one under the new Illicit Drugs program, constituting 83 percent of all 422 delistings in 2023. This rate of deletions greatly outpaces 2022, in which 71 delistings related to drug trafficking represented only 33 percent of the total 218 delistings. This development indicates a U.S. government initiative to delist former narcotraffickers, many of whom have been prosecuted and imprisoned in the United States or their country of origin. Colombian nationals dominated the total removals, accounting for 300 deletions and suggesting that the United States is prioritizing the removal of inactive Cali and Medellín Cartel members from the SDN list.

This delisting effort coincided with the Biden administration’s broader policy shift toward targeting chemical drugs, particularly the synthetic opioids driving overdose deaths in the United States. These simultaneous developments resulted in an overall reduction in the presence of the SDNT and SDNTK listings on the Treasury’s SDN list, suggesting that these sanctions programs have achieved some success in their objectives. The high levels of delistings signal that sanctions targeting illicit drugs trade can be effective in helping disrupt procurement and financing networks to incentivize compliance with U.S. and international law.

Weapons of Mass Destruction

Sanctions designations under the Weapons of Mass Destruction Proliferators (NPWMD) regime more than doubled from 2022 to 2023, with 43 and 100 designations, respectively. Over 90 percent of the NPWMD designations were connected to Iran. Roughly the same number of persons designated for supporting Iran’s WMD program were in Iran (47 designations) as in China (34 designations), as the two countries increasingly cooperate to evade Western sanctions and promote advanced military capabilities. This sanctions pattern indicates a burgeoning economic and defense relationship between Beijing and Tehran. Outside of Iran and China, there were only a few sanctions evasion facilitators designated under this program in Turkey (6 designations), Malaysia (5 designations), Russia (3 designations), Indonesia (2 designations), North Korea (2 designations), and the United Arab Emirates (1 designation). Only seven NPWMD designations did not relate to Iran, targeting five persons in China and two in North Korea. Comparatively, the percentage of NPWMD designations was roughly split in 2022, with 44 percent targeting persons in Russia (19 designations), 30 percent targeting persons in North Korea (13 designations), and 23 percent targeting persons in Iran (10 designations). Evolving current events may have had the strongest influence on the shift from 2022.

In 2023, Iran advanced its nuclear program to unprecedented levels and appeared undeterred by U.S. financial sanctions as the relationship between Tehran and Moscow grew. In comparison, in 2022, Russia launched its war against Ukraine and North Korea conducted 31 missile tests—a record high prompting a stronger U.S. response. Although the Ukraine war is still active, the decrease in NPWMD sanctions targeting Russia could represent a U.S. government shift toward using country-specific sanctions for activities connected to Russia’s WMD program. Additionally, North Korea conducted eight missile launches in 2023. This decline in missile testing most likely contributed to the lower numbers of NPWMD sanctions designations targeting DPRK in 2023.

Corruption and Human Rights

Human rights–related sanctions designations increased from 2022 to 2023, with 41 and 78 designations under the Global Magnitsky human rights program (GLOMAG), respectively. The Biden administration consistently issues higher levels of human rights–related sanctions during years with its flagship Summit for Democracy. Leading up to the inaugural Summit for Democracy in December 2021, the United States levied 176 human rights–related designations, signaling strong support for human rights. In 2022, when no summit took place, designations fell to 41 persons. With the Summit for Democracy II in March 2023, the Biden administration again increased human rights–related designations to 78 persons. It’s worth noting that this remains just above the 2017 through 2020 average of 65.

The United States issued its most significant round of human rights sanctions of 2023 on December 11, 2023, the day after the 75th anniversary of the Universal Declaration of Human Rights. This round of 46 designations, representing 59 percent of the total GLOMAG designations in 2023, targeted a transnational corruption network led by the Rahmanis, two former Afghan government officials known to have misappropriated Afghan state assets and U.S. government funds. In relation to the Rahmanis, the United States sanctioned 23 shell companies in Germany, making Germany the country with the most sanctioned persons under the GLOMAG program in 2023. The country with the second highest number of targeted persons was Bulgaria, where the United States issued government officials and state-owned industries with 11 designations for extensive involvement in entrenched corruption under Russian influence.

Cyber

In 2023, the United States issued 23 designations under its CYBER2 sanctions program. This authority targets malicious cyber-enabled actors and activities, including cyberattacks on critical infrastructure, ransomware attacks and payments, cybercrime, cyberespionage, and organized disinformation campaigns. Sanctions issued under the CYBER2 regime in 2023 continued to build on the novel 2022 designations targeting illicit crypto financing activity. Almost all 23 designations in 2023 were connected to Russia, with only one linked to North Korea. In August, the departments of Justice and the Treasury coordinated to sanction Russian citizen Roman Semenov—one of the three cofounders of Tornado Cash, a “mixer,” or software service that provides anonymity for cryptocurrency transactions by mixing streams of discrete cryptocurrencies. This designation builds on sanctions issued by the United States targeting the Lazarus Group in 2019 and Tornado Cash in 2022 with the goal of disrupting DPRK counterproliferation financing networks that rely on theft and laundering of cryptocurrencies. Mixers pose a unique challenge for sanctions enforcement and offer an alluring environment for illicit financial activity. Typically, the transaction history of a cryptocurrency is tracked in a public, distributed ledger. However, some users—often malign actors—are turning to crypto mixers or tumblers to obscure their transaction history. The designation of Tornado Cash marked the first time the United States sanctioned software, sparking a debate on whether the U.S. government sanctioning authority covers this domain, as it historically targeted only persons and property. The sanctioning of Roman Semenov could be a move to maintain U.S. government sanctioning authority over the primary operations of Tornado Cash.

The remaining cyber sanctions focused on Russia-based cybercrime and were issued in coordination with the United Kingdom. The United States targeted over 20 persons linked to Trickbot Group, a Russia-based cybercrime gang. The Group uses Trickbot—which began as a Trojan virus and evolved into a highly modular malware suite—to deploy a variety of cybercrimes globally, such as ransomware attacks. Activities of the group evolved from stealing financial data in 2014 to launching ransomware attacks targeting U.S. hospitals, government officials, and companies by 2020. These sophisticated attacks aligned the group with Kremlin objectives, once carried out by the Russian Intelligence Services (SVR). The United States has since confirmed that members of the Trickbot Group are associated with the SVR, highlighting the Kremlin’s reliance on this group in the cyber environment. These sanctions were closely coordinated between the United States and the United Kingdom. The United States also sanctioned two persons connected to a Russian Federal Security Service–sponsored advanced persistent threat group that engaged in spear phishing campaigns targeting the U.S. and UK governments.

Other Policy Tools

Entity List

In 2023, the Biden administration continued using the Entity List, maintained by the Department of Commerce’s Bureau of Industry and Security (BIS), to restrict the flow of U.S. goods and technologies to listed foreign companies or individuals. This tool is distinct from the financial nature of Treasury sanctions, which target U.S.-held financial assets and access to the U.S. financial system. Although rarely used until the first Obama administration, the Entity List has emerged as a key foreign policy tool, particularly with respect to containing China’s military and technological advancement and degrading Russia’s military capabilities. In 2022, BIS listed 524 new entities, an all-time high likely inflated due to Russia’s invasion of Ukraine, which prompted an unprecedented number of Entity List designations. Although listings dropped in 2023 to 467 new entities, this remains a very high total from a historical perspective, underscoring the Biden administration’s growing commitment to employing this tool with increasing emphasis.

Russia

On trend with 2022, Russia dominated the Entity List in 2023. A total of 207 entities located in Russia were placed on the Entity List in 2023 for a variety of reasons, 99 percent of which related to the ongoing war in Ukraine. Only three Russian entities were designated for activities unrelated to the Ukraine war—two for arms trade contributing to human rights abuses in Burma and one for facilitating sanctions evasion in Venezuela. The majority of entity listings on Russian persons targeted the Russian military industrial complex, with 191 designations relating to military end users. BIS additionally aimed to stymie sanctions evasion by listing eight Russian companies attempting to acquire sensitive U.S.-origin items. A final five entities were designated for Russian filtration operations, including companies that contribute biometric technology involved in suppressing Ukrainian resistance. Commerce further expanded its Russia-related listings beyond Russia’s borders, with 107 entities outside of Russia listed as a result of activities related to the war in Ukraine and associated sanctions evasion. These extraterritorial designations touch 21 countries in total and represent 35 percent of Russia-related listings.

The Biden administration used diverse economic tools to stymie Russian arms trade in 2023. BIS increasingly applies the Foreign Direct Product Rules (FDPR) to sanctioned entities in Russia, allowing BIS to prevent the transfer of products made in third-party foreign countries using U.S. technology. The Biden administration levied an FDPR on 246 entities in Russia in 2022, including two entities initially designated under the Obama administration and one initially designated under the Trump administration. Likewise, BIS listed 181 entities in Russia with FDPR license requirements in 2023, amounting to 87 percent of total Russia-related 2023 listings. Nonetheless, Russia continues to purchase U.S.- and ally-origin technology through third-party country conduits and intermediaries. China hosted the majority of entities listed for assisting Russian entities evade sanctions, with 60 entities. Other third-party intermediaries were located in Iran (7 entities), Armenia (5 entities), Finland (4 entities), India (4 entities), Germany (3 entities), the United Arab Emirates (3 entities), Turkey (3 entities), and Uzbekistan (3 entities). BIS also targeted the increasingly coordinated sanctions evasion and military trade between China, Iran, and Russia, listing 7 entities for China-Russia cooperation, 10 entities for Iran-Russia cooperation, and 2 entities for Iran-China cooperation.

China

China-related designations ranked second highest in Entity List designations in 2023, with 78 designations across a range of technology, aerospace, and marine science companies. Several Commerce designations and BIS rules targeted specific sectors and People’s Liberation Army (PLA) programs. After a Chinese high-altitude spy balloon flew across United States airspace in early 2023, Commerce designated six entities in February for contributing to the PLA’s aerospace programs. The associated BIS rule explicitly targets high-altitude balloon development and production for intelligence and reconnaissance capabilities. On October 17, 2023, BIS issued export controls on 13 entities, aiming to restrict China's ability to acquire the advanced computing integrated circuits used in the development of frontier artificial intelligence (AI) innovations applicable to the PLA’s WMD and conventional weaponry modernization. This round of designations added to BIS rules issued in October 2022 targeting China’s advanced computing and semiconductor sectors. In several rounds of rules throughout 2023, Commerce also targeted China’s biomedical surveillance and genetic data collection programs, which contribute to the repression of ethnic minorities, including the Uyghur population in Xinjiang. BIS named a total of 10 entities for contributing to China’s campaign of human rights abuse, mass arbitrary detention, and high-technology surveillance against the Uyghur people in 2023.

From 2020–2023, the Biden administration has already designated more Chinese entities on the Entity List than were designated for the entirety of the Trump administration. The Biden administration has designated 303 Chinese entities, outpacing the Trump administration’s record 260 Chinese entity designations. Likewise, the Biden administration increasingly uses FDPR to dampen the flow of foreign products made using U.S. technology to blocked entities in China. During the Trump administration, Commerce created the novel FDPR and initiated its use against Chinese telecommunications giant Huawei Technologies and 47 Chinese subsidiaries, though the use was limited to just this one case. Biden has listed 80 Chinese entities with FDPR license requirements in addition to retroactively applying FDPR requirements to 18 Chinese entities initially listed by the Bush, Obama, and Trump administrations. Biden’s hefty total of 98 Chinese entity listings with FDPR license requirements suggests his administration is leveraging the outsized role of U.S. technology and tools in supply chains around the world as a choke point in an attempt to slow China’s military modernization, particularly as it relates to microelectronics. The Entity List trend is consistent with SDN designations on Chinese persons across the administrations, with the Biden administration issuing 219 SDN designations (160 entities and 59 individuals) to date compared to the Trump administration’s 205 SDN designations (112 entities and 93 individuals).

Pakistan

In 2023, the third most common reason for Entity List designations was association with Pakistan’s ballistic missile and nuclear program. Commerce targeted 29 entities located in Pakistan and China for supplying unsafeguarded nuclear activities. The majority of Pakistan-related designations were located in China, Pakistan’s largest arms supplier and its third-largest trading partner. By fostering the strategic modernization of Pakistan’s military, China aims to counterbalance the challenge of a rising India and reduce U.S. regional leverage.

Additional Entity Listings

The fourth-largest category of Entity List designations in 2023 targeted military supply chains that contribute to global human rights abuse. A total of 16 entities were listed for human rights–related reasons. In addition to Chinese entities responsible for repression against the Uyghur people (7 designations), Commerce targeted entities that supply the military regime in Burma (8 designations) and designated the Nicaraguan National Police for human rights abuse against pro-democracy opposition protestors (1 designation).

SDN General Licenses

Throughout 2023, the Biden administration used general licenses to balance competing foreign policy and national security aims. General licenses authorize otherwise prohibited transactions with sanctioned individuals or entities without delisting them from the Treasury’s SDN List. They are frequently used for humanitarian carveouts. In 2023, general licenses for Sudan and the western Balkans were authorized for humanitarian purposes, facilitating the delivery of agricultural commodities, food, medicine, and water. The Treasury also issued general licenses for certain Belarusian and Russian entities to protect U.S. industry and financial institutions by allowing them to wind down activities or divest debt or equity from sanctioned entities.

In some instances they have also been used by the U.S. government as a foreign policy carrot, such as when they were issued to allow for certain trade with Iran after the nuclear deal. In a notable recent use of general licenses, the Biden administration paired gradual sanctions relief with behind-the-scenes diplomacy to incentivize the Venezuelan government to negotiate with the U.S.-backed opposition. The administration tested this positive reinforcement strategy on November 26, 2022, issuing a general license to Chevron to resume oil production in Venezuela on the same day that the Maduro government returned to negotiations with Venezuelan opposition in Mexico City. This policy served the secondary purpose of reintroducing Venezuelan oil to U.S. markets, filling supply gaps created by the Russian oil embargo. Later, on October 17, 2023, Venezuelan government and opposition delegates in Barbados reached an accord pledging respect for certain electoral freedoms and guarantees. The next day, October 18, the United States announced general licenses on Venezuelan oil, gold, minerals, and bonds markets, rolling back certain Trump-era sanctions. However, since the issuance of general licenses, Maduro’s government has increased repression and engaged in nationalistic saber-rattling against Guyana, casting doubt on the durability and effectiveness of the sanctions relief.

Oil Price Cap

The oil price cap is an innovative sanctions tool designed to reduce Russian energy export revenue while maintaining stability in global energy markets. The price cap leverages U.S. and partner country dominance in global shipping insurance markets to impose a cap on the price of seaborne energy products, prohibiting the provision of insurance for vessels carrying products priced above the cap. The Price Cap Coalition, comprising the United States, EU, G7, and Australia, implemented the first step of the price cap policy in December 2022 by setting a cap of $60 per barrel for crude oil of Russian origin. The Coalition then implemented a cap on refined products that trade at a premium to crude, like diesel, at $100 per barrel, and products that trade at a discount, such as fuel oil and naphtha, at $45 per barrel. The policy was designed to allow “services providers in the Coalition to participate in trade of seaborne Russian-origin oil to third countries only if the oil is traded below the cap—and [provide] importers outside the Coalition with the leverage to negotiate heavy discounts on Russian oil.”

While an important case of sanctions innovation, the oil price cap is proving challenging to enforce, as indicated by the wave of general licenses, updated guidance, and designations the United States issued beginning in October through December 2023. The Treasury imposed sanctions on eight persons related to the price cap during this period, in addition to targeting eight vessels shipping oil to be sold at prices that exceeded the cap. All of these designations are linked to Liberia, Russia, Turkey, or the United Arab Emirates through ownership or vessel flag. The Coalition faces challenges associated with implementing and enforcing the price cap, with more sanctions likely to follow in 2024. For additional information on the oil price cap, read Sanctions by the Numbers: The Russian Energy Sector.

Digital Assets and Sanctions Enforcement

The crash of FTX, one of the largest cryptocurrency exchanges, heightened policy debates about the need for stronger oversight of the digital assets industry in 2022. Digital assets present a novel means for malign actors to finance criminal activity, including money laundering, arms proliferation, terrorism, and sanctions evasion. These concerns grew in 2023 after Binance, formerly the world’s largest crypto exchange, pleaded guilty to three charges related to violations of anti–money laundering and sanctions laws. Binance agreed to pay a $4.3 billion fine—one of the largest settlements in U.S. history. Additionally, the founder and CEO of Binance, Changpeng Zhao, pleaded guilty to money laundering violations and agreed to pay a $50 million fine as well as to step down from the exchange. Although the U.S. government did not sanction any persons connected to Binance, the hefty fine signals clear government intent to use a range of enforcement authorities to address illicit behavior in the digital assets ecosystem.

Looking Ahead

The historically high level of sanctions designations in 2022 and 2023 demonstrate the growing prominence of these measures as a foreign policy tool. In response to the ongoing war in Ukraine, the Biden administration continued to expand sanctions—often in coordination with allies in the G7, EU, and others—targeting critical sectors in Russia, such as defense, finance, and energy. Russia continues to be the most sanctioned country in the world, a status it obtained in March 2022. The United States maintained its upward trajectory of issuing Entity List designations, primarily targeting Russia and China, as an additional leaver to achieve its foreign policy and national security goals, and this trend will likely continue.

With wars raging on multiple continents and increasing global connectivity and alternative platforms facilitating malign activities, sanctions will certainly continue to play a significant role in U.S. foreign policy through 2024. If 2023 patterns continue, the Biden administration will likely continue to focus on enforcing and expanding existing Russian sanctions and export controls. U.S. government resources will prioritize enforcement and addressing evasion, overseeing the oil price cap, and imposing secondary sanctions on non-U.S. banks that hold Russian assets and facilitate transactions for Russia’s military procurement network. The United States may work with partners to break new ground by moving beyond freezing Russian sovereign assets to actively seizing these assets or interest gained from them to fund Ukrainian resistance and rebuilding efforts. On China, the Biden administration can be expected to continue using export controls, including Entity List designations, as the primary tool to manage intensified U.S.-China economic competition. Direct diplomacy between Washington and Beijing remains a Biden priority, and it is unlikely that the United States will create a China-specific sanctions regime so long as diplomatic progress continues. The Biden administration will likely also maintain sanctions pressure on Iran and its proxies as Iran continues to advance support for Hezbollah, Houthi rebels, and Hamas amid war in Israel and Gaza.

Methodology

The term “person” throughout this document denotes an individual or entity, excluding aircraft and maritime vessels. (Entries in the Sanctions by the Numbers series prior to 2022 have included aircraft and maritime vessels.) Sanctions designations often overlap with several different sanctioning authorities, including country-specific and thematic sanctions programs. In the case where a single designation is pursuant to multiple sanctioning authorities, the designation was counted once within the total designation number but attributed to each pursuant sanctioning authority. For example, if the United States designated Entity X pursuant to NPWMD and IFSR, then that single designation was recorded once for the total designation of U.S. sanctions but contributed to both the NPWMD and IFSR designation counts.

All U.S. government designations and delistings were drawn from the following OFAC sanctions programs: BALKANS, BALKANS-EO14033, BELARUS, BELARUS-EO14038, BPI-RUSSIA-EO14024, BURMA-EO14014, CAATSA-IRAN, CAATSA-RUSSIA, CAR, CYBER2, DPRK, DPRK2, DPRK3, DPRK4, DRCONGO, ELECTION-EO13848, GLOMAG, HOSTAGES-EO14078, HRIT-IR, IFSR, ILLICIT-DRUGS-EO14059, IRAN, IRAN-CON-ARMS-EO, IRAN-EO13846, IRAN-HR, IRAN-TRA, IRAQ2, IRGC, MAGNIT, LEBANON, NICARAGUA. NPWMD, PEESA-EO14039, RUSSIA-EO1402, RUSSIA-EO14065, SDGT, SDNT, SDNTK, SOMALIA, SOUTH SUDAN, SUDAN-EO14098, SYRIA, SYRIA-CAESAR, SYRIA-EO13894, TCO, UKRAINE-EO13660, UKRAINE-EO13661, UKRAINE-EO13662, UKRIANE-EO13685, and ZIMBABWE, issued from January 1, 2023, through December 31, 2023. All information regarding additional sanctions, export controls, and other economic measures from the departments of Commerce and State were drawn from public government sources: Federal Register notices, press releases, and the BIS Entity List.

Although the departments of State and the Treasury coordinate closely on sanctions policy and implementation and each has its own sanctions authorities, this report does not make a distinction between the two for analysis purposes. Regardless of which agency has the authority, any sanctions that resulted in persons being put on the SDN list are included in this analysis. Any sanctions that did not result in placement on the SDN list are not included. Analysis categorizes designations related to Hong Kong and Macau under China.

Furthermore, the analysis also calculates Entity List designations, which are administered by the U.S. Department of Commerce’s Bureau of Industry and Security. Though SDN and Entity List designations often complement each other in conjunction with other U.S. foreign policy tools, the two lists are independent and each maintained separately.

Where possible, the report notes if a sanctioned entity has made a public statement or response to their designation on one of the sanctions lists. Companies that issued statements in response to the sanctions include only Binance. Binance’s statement can be read here.

Acknowledgments

The authors would like to acknowledge the Center for a New American Security (CNAS) Communications and Publications teams for their support, design, and edits. The authors would also like to thank John Hughes, adjunct senior fellow with the Energy, Economics, and Security Program at CNAS, and Emily Kilcrease, senior fellow and director of the Energy, Economics, and Security Program at CNAS, for their reviews of various iterations of the report. This report was made possible with general support to the Energy, Economics, and Security Program.

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