Sanctions by the Numbers: 2024 Year in Review

SDN List Designations

Specially Designated Nationals and Blocked Persons (SDN) List designations in 2024 targeted a wide range of activities contrary to American national security and foreign policy interests. The Biden administration added a total of 3,135 persons to the SDN List in 2024, a notable increase from the 2,502 persons added in 2023.

The Treasury Department levied the highest number of SDN designations on Russian individuals and entities for the third consecutive year, with 1,706 designations. Five additional countries received more than 100 designations: China (276 designations), Iran (130 designations), the United Arab Emirates (119 designations), Turkey (109 designations), and Mexico (102 designations). Although China received the second-highest number of SDN designations overall in 2024, all Chinese persons added to the SDN List were designated under Russia-, Belarus-, or Iran-related authorities or under thematic sanctions authorities. This is consistent with prior years’ trends, in which the number of Chinese persons on the SDN List increased substantially but with virtually all of these sanctions addressing malign activities outside of China. The United States has been hesitant to develop and implement a robust SDN sanctions framework targeting the People’s Republic of China (PRC) due to concerns about the potential ramifications on the bilateral relationship and global economy.

Country-Specific Financial Sanctions

The United States imposes sanctions under country-specific authorities to target the policies and actions of a particular government or actors associated with a country that undermine American national security and foreign policy interests. While most sanctions issued under country-specific authorities in 2024 targeted longstanding U.S. adversaries like Russia, Iran, and North Korea, geopolitical developments ensured there were also notable numbers of designations aimed at countering malign activities in countries such as Belarus and Venezuela, along with designations on Israeli settlers in the West Bank.

Russia

In 2024, 70 percent of SDN List designations were made under a Russia-related sanctions authority. The United States, often in coordination with allies and partners, issued sanctions targeting Russia’s energy and finance sectors, military-industrial complex, chemical and biological weapons programs, and sanctions evasion networks. Notably, 2024 marked the first time that the United States designated Chinese companies for supplying complete weapons systems—rather than military-industrial components or inputs—to Russian firms. Russia-related sanctions in 2024 also targeted actors involved in malicious cyber activities, aiding North Korean military efforts, and undermining democratic processes in Belarus and the United States.

Third-Party Evasion and Support Networks

Despite past U.S. efforts to counter Russian evasion networks, Russia continued to receive critical military inputs, dual-use goods, and financial support from abroad. Building on the United States’ sanctions strategy toward Russia put forth in early 2023, the Treasury Department focused on striking “at [Russia’s] remaining avenues for international materials and equipment, including their reliance on critical supplies from third countries.” The Treasury Department’s Office of Foreign Assets Control (OFAC) designated 70 non-Russian nationals and 459 entities with non-Russian addresses (including 14 entities that had addresses both inside and outside of Russia). These 529 persons spanned 55 third-party countries, with the highest number of these designations levied on Chinese persons.

Sanctions on non-Russian persons under Russia-related authorities grew significantly between 2022 and 2024, reflecting mounting concerns over Russia’s attempts to circumvent sanctions. To further crack down on Russia’s evasion networks, the Treasury broadened its authority to sanction foreign financial institutions supporting Russia’s war effort. As of June 2024, any foreign financial institution that conducts a transaction on behalf of a person blocked pursuant to Executive Order 14024 is now subject to being sanctioned. However, as of publication, OFAC has not placed secondary sanctions on any foreign banks under this authority.

Energy and Finance

In 2024, the United States continued to ratchet up pressure on Russia’s energy and finance sectors, which provide vital funds to Russia’s war efforts in Ukraine, most notably by designating Gazprombank and its six foreign subsidiaries. Gazprombank is partially held by Kremlin-owned gas company Gazprom and serves as a channel through which the Russian government facilitates many of its military-related financial activities as well as energy payments. The United States also imposed sanctions on persons contributing to the development of future Russian energy capabilities, including the Arctic Liquified Natural Gas (LNG) 2 project, the Vostok Oil project, and the Yakutia LNG project.

The Treasury Department took its most aggressive steps since the start of the war in Ukraine to target Russia’s energy sector during the final month of the Biden administration (the following actions are not included in this report’s numbers, as they fall outside the period and scope of analysis). This included authorizing sanctions on any person operating in Russia’s energy sector and simultaneously sanctioning two major Russian oil producers and over 180 vessels involved in the illicit trade of Russian oil. The Treasury Department also amended a general license to tighten restrictions on energy-related transactions with certain sanctioned Russian banks and designated over 150 entities and individuals that operate in Russia’s defense, finance, and energy sectors, or are part of Russian evasion networks.

Iran

The United States levied 236 designations under Iran-specific SDN authorities, many of which targeted persons involved in illicit revenue-generating schemes, procuring goods for the Iranian military-industrial base, and supplying equipment and components to the Russian military. Designations in 2024 also targeted persons supporting critical sectors of Iran’s economy, including construction, mining, manufacturing, and textiles, as well as entities that engaged in significant sales of Iranian petroleum and petrochemical products. The United States, often in coordination with Canada and Australia, also sanctioned persons responsible for human rights violations and political repression in Iran. Many designations targeted members of the Islamic Revolutionary Guard Corps (IRGC), a branch of Iran’s military created in 1979 to oversee its ballistic missile arsenal and the Quds Force, which works with Iran’s regional affiliates, like Hezbollah and Hamas.

North Korea

The United States issued 29 designations under North Korea–related sanctions authorities, several of which reinforced long-standing efforts to disrupt funding the Kim regime uses to finance North Korea’s weapons of mass destruction (WMD) program. Other sanctions targeted key officials in the Korean People’s Army (including generals accompanying North Korean troops deployed to support Russia in Ukraine), Russian entities shipping petroleum to North Korea, and persons facilitating the transfer of financial and military assistance between Russia and North Korea. North Korea’s ties with Russia became a significant concern in 2024 following the signing of a landmark mutual defense treaty and reports of North Korean soldiers being deployed to support Russia in Ukraine.

Other Country-Specific Sanctions Authorities

The Biden administration also used financial sanctions to address concerns with developments in Belarus (55 designations), Venezuela (37 designations), and the West Bank (33 designations). Sanctions under Belarus-specific authorities targeted Belarus’s ongoing support for Russia’s invasion of Ukraine and revenue streams of Belarusian oligarchs that support the Lukashenko regime. Additionally, the United States used the Venezuela-related sanctions authority for the first time since 2021 in response to President Nicolas Maduro’s victory in the fraudulent 2024 Venezuelan elections. Then–President Joe Biden also issued a new executive order (EO)—which the second Trump administration revoked—authorizing sanctions against Israeli settlers and others responsible for destabilizing activities in the West Bank.

Thematic Financial Sanctions

Thematic sanctions authorities aim to counter transnational activities that undermine U.S. interests rather than actors in a particular country. The majority of thematic sanctions in 2024 targeted persons facilitating acts of terror, illegal drug production and trafficking, and WMD proliferation. Most designations made under nonproliferation authorities reinforced sanctions targeting Iran’s and North Korea’s military capabilities issued under country-specific authorities.

Counterterrorism

Nearly half of all thematic sanctions in 2024 were made under counterterrorism-related authorities, marking the third consecutive year that this represented the most frequently used thematic authority. Iran accounted for most counterterrorism sanctions, with 58 designations in 2024, compared to just 16 in 2023. Following Iran’s April 13, 2024, attack on Israel, the United States sanctioned 17 Iranian persons supporting Iran’s ballistic missile and unmanned aerial vehicle (UAV) programs and proliferating UAVs to the IRGC’s regional affiliates. The United Kingdom concurrently imposed sanctions targeting Iran’s military-industrial base. Other Iranian persons sanctioned under counterterrorism-related authorities engaged in malicious cyber activities on behalf of the IRGC.

Beyond Iran, terrorist evasion networks were a prominent target of counterterrorism sanctions in 2024. China received the second-highest number of designations under counterterrorism-related authorities in 2024, underscoring concerns about the role of Chinese entities—especially in Hong Kong—in illicit terrorist financing networks. The Yemen-based Houthis became an increasingly frequent recipient of counterterrorism sanctions as the group persisted in its attacks on U.S. vessels in the Red Sea. Sanctions aimed at countering the Houthis not only targeted Yemeni persons but also sought to disrupt the transnational network of Houthi financier Sa’id al-Jamal. Additionally, the Biden administration maintained its focus on sanctioning Hamas networks, designating 12 Palestinian persons in January for transferring funds, including cryptocurrency, from the IRGC to Hamas. The United Kingdom and Australia concurrently sanctioned several Hamas officials. In March, the United States and United Kingdom coordinated to sanction a London-based Hamas fundraising network.

Drug Trafficking

The number of persons sanctioned for their involvement in the illicit drug trade fell from 192 in 2023 to 138 in 2024. Mexico has accounted for the overwhelming majority of counternarcotics sanctions over the past two years, with the Sinaloa and Cartel Jalisco Nueva Generación (CJNG) cartels being the predominant targets due to their central role in the production and trafficking of fentanyl and other synthetic drugs. The 2024 National Drug Threat Assessment notes the Sinaloa and CJNG cartels are “at the heart” of the synthetic drug crisis in the United States. Colombia accounted for the second-highest number of counternarcotics sanctions in 2024, the majority of which targeted Clan del Golfo, one of the largest cocaine trafficking organizations in the world.

It is also worth noting that the number of Chinese persons designated for their roles in the illicit drug trade dropped sharply from 44 in 2023 to just 2 in 2024. This may have been the result of an agreement between President Biden and Chinese Communist Party General Secretary Xi Jinping on resuming counternarcotics cooperation in November 2023, which led to the launch of the U.S.-PRC Counternarcotics Working Group in January 2024.

On January 20, 2025, President Donald Trump issued an executive order establishing a process for designating drug cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). This designation would significantly expand the risk of sanctions for persons engaging with drug cartels. Members of Congress and past administrations have considered designating drug cartels as FTOs or SDGTs but decided not to do so due to concerns about the potential ramifications on U.S.-Mexico relations and American businesses.

Human Rights and Corruption

In 2024, 57 persons were sanctioned under authorities targeting those facilitating human rights abuses and engaging in corruption. This marked a significant decrease from the 173 designations levied in 2021, when the first Summit for Democracy was held. Despite this, the United States used other sanctions authorities to address human rights concerns.

Ahead of the third Summit for Democracy last year, the United States issued its first sanctions against actors proliferating commercial spyware under sanctions authorities aimed at countering malign cyber activities. These designations targeted the Intellexa Consortium, a network of companies responsible for developing the Predator spyware. Predator and other commercial spyware have been used by malign actors seeking access to sensitive U.S. data and by authoritarian regimes to surveil their citizens and target dissidents. The sanctions were supplemented by a diplomatic push by the United States to counter the spread of commercial spyware during the third Summit for Democracy, which focused significantly on the impact of technology on democratic institutions.

Human rights and corruption–related sanctions in 2024 targeted persons affiliated with the Houthi prison system and persons in Zimbabwe, Cambodia, Georgia, Guyana, Uzbekistan, Haiti, and Russia. In March 2024, President Biden signed an executive order revoking EOs that authorized Zimbabwe-specific sanctions, resulting in the removal of 121 persons from the SDN List. Concurrently, 12 persons affiliated with the Zimbabwean government, including the president of Zimbabwe, who had been sanctioned under these EOs prior to 2024, were redesignated under the United States’ human rights and corruption–related sanctions authority. These actions were seemingly an effort to address concerns about the humanitarian impact of the sanctions imposed under the revoked Zimbabwe-related EOs.

Malicious Cyber Activities and Election Interference

The number of persons sanctioned for engaging in malign cyber activities nearly doubled between 2023 and 2024. Russia received the most cyber-related designations in 2024, which targeted a Russian national involved in a ransomware attack against an Australian healthcare insurer and members of Russian ransomware, hacktivist, and cybercrime groups.

In 2024, China was the second-largest recipient of sanctions for malicious cyber activities. These sanctions targeted persons responsible for cyberattacks on U.S. critical infrastructure providers and spreading malware that cost the U.S. government billions. 2024 marked the first time since 2020 that the United States sanctioned malign Chinese cyber actors. These sanctions were issued under EOs 13694 and 13757, which target a broad range of malicious cyber activities, including efforts by foreign actors to interfere in U.S. elections through the spread of disinformation. EO 13848 authorizes sanctions on a broader range of activities that undermine the electoral process, targeting those that “have directly or indirectly engaged in, sponsored, concealed, or otherwise been complicit in foreign interference in a United States election.” Ten persons affiliated with the IRGC and Russian intelligence were designated under EO 13848 for interfering in the 2020 and 2024 Presidential elections.

Although outside the period of analysis of this report, toward the end of 2024, Chinese hackers compromised the Treasury Department, including OFAC, which oversees U.S. financial sanctions. One of the final series of sanctions issued by the Biden administration in early 2025 targeted persons who were involved in this cyberattack.

Entity List Additions

In 2024, the Entity List remained central to the United States’ efforts to curb the flow of goods and technologies to persons contributing to the Russian military-industrial complex and supporting the PRC’s technological and military ambitions. The Commerce Department added a total of 520 persons to the Entity List in 2024, representing a notable increase from the nearly 470 entities added in 2023.

China

Two hundred sixty-three Chinese persons were placed on the Entity List in 2024, accounting for slightly over half of all persons added. Notably, this meant that the number of Chinese persons added to the Entity List on a yearly basis surpassed the number of Russian persons for the first time since the outbreak of the war in Ukraine. The administration’s additions of Chinese persons predominately sought to counter the PRC’s military modernization efforts and its deepening ties with Russia and Iran.

Roughly half of the Chinese persons placed on the Entity List in 2024 (132 entities) were added for their contributions to China’s advanced semiconductor industry. These Entity List additions build on a years-long effort to slow China’s chip advances, including a 2024 expansion of broader technology-based semiconductor-related export controls introduced in 2022 and 2023. The Biden administration’s efforts to control the flow of advanced semiconductors culminated in the release of the novel AI diffusion rule on January 13, 2025.

The Commerce Department added 55 persons for their contributions to other aspects of the PRC’s military modernization efforts. This included at least 22 Chinese persons bolstering the PRC’s quantum capabilities and 11 Chinese persons involved in the PRC’s high-altitude balloon program. Other persons were added for contributing to the PRC’s UAV program, training Chinese military pilots, and procuring U.S.-origin items and technologies for Chinese military end users.

The United States’ use of the Entity List in 2024 also reflects concerns about the PRC’s support of the Russian and Iranian military-industrial bases. The Commerce Department added 59 Chinese persons to the Entity List for supporting the Russian war effort. These persons supplied Russian military end users with items such as electronics, microelectronics, machine tools, UAV components, and other controlled items to Russia. In an effort to crack down on evasion, the Commerce Department issued a rule in June 2024 stating that it would begin adding the addresses used by shell companies to the Entity List rather than the names under which they operate. Fifteen addresses based in China involved in the “transshipment of sensitive goods” to Russia were added to the Entity List because of this rule, on top of the 59 Chinese persons noted above. Additionally, the Commerce Department placed several Chinese persons involved in procuring items for Iran’s WMD and UAV programs and components for Shahed-series drones for the Iranian and Russian militaries on the Entity List.

In addition to the surge in Chinese persons being added to the Entity List, the Biden administration also dramatically expanded its use of Foreign Direct Product Rules (FDPRs) in 2024. FDPRs are extraterritorial export controls placed on foreign-made goods that are produced using U.S. machinery or software. The Biden administration applied an FDPR to 105 Chinese entities, slightly more than doubling its average of roughly 50 FDPR applications in 2022 and 2023. Of these 105 entities, 89 had an FDPR pertaining to Russian and Belarusian military end users applied to them, underscoring the administration’s increasing concern with Chinese companies’ role in supplying the Russian military-industrial base. Additionally, a newly created FDPR targeting entities supporting the PRC’s advanced semiconductor capabilities was applied to the remaining 16 Chinese entities.

Russia

In 2024, the Commerce Department placed a total of 147 Russian persons on the Entity List, a marked decline from the 207 it added in 2023 and significantly fewer than the 374 that were added in 2022. Despite this consistent decrease in Russian persons being added to the Entity List, Russia still accounted for the second-highest number of additions to the Entity List in 2024. Commerce added a total of 140 Russian persons that operated within the Russian military-industrial base, procured items and technology with military applications, or violated U.S. export controls and sanctions on Russia. Several of these persons contributed to Russia’s chemical and biological weapons and UAV programs.

The Commerce Department also intensified its efforts to crack down on Russian evasion networks, with a prominent focus on Chinese persons. A total of 135 non-Russian entities were listed for supporting Russia’s war effort by violating sanctions and export controls on Russia and contributing to the Russian military-industrial base, including the 59 Chinese persons noted above. Chinese persons accounted for the majority of non-Russian persons placed on the Entity List for supporting Russia’s military-industrial base. An additional 9 Russian persons and 22 non-Russian persons were added to the Entity List for violating export controls and sanctions on both Russia and Iran or for contributing to these countries’ productions of Shahed-series drones.

The Commerce Department also continued to use FDPRs to attempt to curb the flow of certain foreign goods and technologies to Russia. The Commerce Department broadened the scope of the FDPR targeting Russian and Belarusian military end users, making it now also applicable to “Russian or Belarusian procurement entities.” The expanded Russia/Belarus-Military End User and Procurement FDP rule applies to entities that pose “a significant risk of involvement in the supply or diversion of items . . . to procurement networks for Russia’s or Belarus’s defense industry or intelligence services.” Apart from the FDPRs, the Commerce Department also tightened restrictions on the export of software and industrial items to Russia and Belarus under the Export Administration Regulations.

Other Entity List Additions

The United States also used the Entity List as a complement to financial sanctions and to reinforce concerns about the flow of sensitive goods and technologies to nations other than China and Russia. The Commerce Department added 16 Pakistani persons contributing to Pakistan’s ballistic missile, cruise missile, and strategic UAV programs. Additionally, in April, two persons based in the United Arab Emirates were placed on the Entity List for violating U.S. export controls on Iran.

The United States also used the Entity List to reinforce its efforts to target those responsible for human rights violations and antidemocratic activities with financial sanctions. Entity List additions included two Chinese persons for supplying goods and services to the PRC’s public security apparatus and facilitating abuses against ethnic minorities. Two Russian persons were added for supplying goods to Burma’s military regime, and two others for providing facial recognition software the Russian government uses to monitor and track protestors and dissidents. This seemingly marked the first time since Russia’s invasion of Ukraine that Russian persons were placed on the Entity List specifically for facilitating human rights violations within Russia. (The United States has placed Russian persons on the SDN List for their involvement in human rights abuses within Russia following the outbreak of the war, including those involved in the poisoning of opposition politician Aleksey Navalny.) Other human rights–related Entity List additions targeted Burmese entities affiliated with the military regime and a multinational company supplying the Egyptian government with surveillance and censorship technology.

Looking Ahead

In 2025, the United States’ use of sanctions may shift in some notable ways under a new administration that has clearly indicated that it views tariffs as a key tool for protecting economic and national security. Tariffs may be used alongside or even instead of sanctions. The United States’ approach to sanctions on Russia is likely to shift, with the Trump administration pushing for a speedy resolution of the conflict in Ukraine. Additionally, if trends from the first Trump administration carry over into the second, there may be an increase in sanctions targeting the PRC and North Korea. The signing of a National Security Presidential Memorandum in early February directing the treasury secretary to “impose maximum economic pressure” on Tehran suggests that this is likely to be the case for Iran. The second Trump administration may also build on the first Trump administration’s and the Biden administration’s efforts to address competition with China through export controls. The United States’ use of coercive economic statecraft will continue to evolve amid escalating geopolitical conflict and political transitions around the world.

Terminology & Methodology

Terminology

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 included aircraft and maritime vessels under the definition of “entity.”)

“PRC” refers to the Chinese state. “China” means the entire country, inclusive of nongovernment and nonparty actors. When discussing economic activity, the default term is also “China,” to encompass the range of individuals, firms, and government entities that may be involved in economic activity.

The Specially Designated Nationals and Blocked Persons List is maintained by the Department of the Treasury’s Office of Foreign Assets Control. An SDN designation represents the United States’ most stringent financial sanction, prohibiting U.S. persons from engaging in any transaction with the designated individual or entity and freezing all U.S.-based assets associated with them.

The Entity List is maintained by the Commerce Department’s Bureau of Industry and Security (BIS). It is used to restrict or prohibit the export of U.S. goods and technologies to listed persons.

Foreign Direct Product Rules are extraterritorial export controls that control trade in foreign-made goods if these goods are made using U.S. software or equipment.

Methodology

All U.S. government designations and delistings were drawn from the following OFAC sanctions authorities: BALKANS-EO14033, BELARUS-EO14038, BPI-RUSSIA-EO14024, BURMA-EO14014, CAATSA-IRAN, CAATSA-RUSSIA, CAR, CYBER2, DPRK2, DPRK3, DPRK4, DRCONGO, ELECTION-EO13848, GLOMAG, HOSTAGES-EO14078, IFSR, ILLICIT-DRUGS-EO14059, IRAN, IRAN-CON-ARMS-EO, IRAN-EO13846, IRAN-EO13871, IRAN-EO13902, IRGC, IRAN-HR, IRAN-TRA, LEBANON, NICARAGUA, NPWMD, NS-PLC, RUSSIA-EO14024, SDGT, SOMALIA, SOUTH SUDAN, SUDAN-EO14098, SYRIA, SYRIA- CAESAR, SYRIA-EO13894, TCO, UHRPA, UKRAINE-EO13662, VENEZUELA, and WEST-BANK-EO14115. All information regarding additional sanctions, export controls, and other economic measures from the Departments of Commerce, State, and the Treasury were drawn from public government sources: Federal Register Notices, press releases, and the BIS Entity List. Data on the specific illicit activity associated with SDN and Entity List designations and additions is taken from OFAC press releases and BIS Federal Register Notices.

There is some uncertainty in quantifying SDN designations by policy priority because U.S. government press releases do not always discuss the sanctionable activity that leads to each designation. For instance, in a round of U.S. government sanctions, there may be 100 designations but only 50 that are called out and explained in the press release. In this case, the report records “at least” 50 designations pursuant to the particular policy priority or illicit activity discussed in the press release.

The authors use the justifications given by the BIS in the Federal Register Notices to determine the reason why a specific Entity List addition was made. For example, they count persons as being placed on the Entity List for contributing to China’s military modernization efforts if the BIS explicitly states they are listing the person for (1) providing goods and technologies to Chinese military end users or People’s Liberation Army authorities, or (2) diverting goods and technologies to China that have potential military applications. Some persons were added to the Entity List for more than one reason. They are counted once in the total number of entities added to the list but are included in the count for each specific reason they were listed.

The Center for a New American Security’s Energy, Economics, and Security Program (EES) uses nationality to determine the country of an individual placed on the Specially Designated Nationals and Blocked Persons List. This, however, may not necessarily reflect the country of residence or country of origin of an individual. For example, EES would categorize a person of Syrian origin who is a Canadian national under “Canada.” To minimize double counting, in cases where an individual has more than one nationality, EES uses information provided by OFAC to make the best possible determination of their primary nationality.

EES uses physical addresses to determine how to categorize entities placed on the SDN List. In instances in which the entity has an address in multiple countries, the entity is labeled under each country in which it is located. For example, an entity based in China and Switzerland would be counted as both a Chinese and a Swiss entity.

To avoid double counting, in the section of this report examining SDN sanctions under Russia-related authorities, the term “Russian persons” includes all entities with at least one address in Russia. “Non-Russian persons” includes all persons without an address in Russia. For example, in this section of the report, a company with an address in China and Russia is counted as “Russian” and “Chinese”; a company with only an address in China is counted as “non-Russian” and “Chinese.”

Subsidiaries are listed separately on the Entity List and are therefore counted as discrete designations in this data. For instance, in 2020, the total number of designations to which a Foreign Direct Product Rule was applied is entirely attributable to Huawei Technologies and its subsidiaries. For SDN designations, subsidiaries may be listed separately or may be captured under OFAC’s 50 percent rule, which automatically applies the SDN restriction to entities in which the blocked person owns 50 percent or more. In the latter case, EES counts only one designation for the listed person and any additional persons captured under the 50 percent rule.

Sanctions designations often overlap with several different sanctioning authorities, including country-specific and thematic sanctions authorities. In the case where a single designation is pursuant to multiple sanctioning authorities, the designation is counted once within the total designation number but attributed to each pursuant sanctioning authority. For example, if the United States designated Entity X, located in China, pursuant to GLOMAG and HK-EO13936, then that single designation is recorded once for the total designation of U.S. sanctions but contributes to both the GLOMAG and HK-EO13936 designation counts.

Sanctions numbers for Hong Kong and Macau are included within the total China numbers for this report. This report refers to the executive order targeting destabilizing activities in the West Bank as a country-specific authority as it is aimed at countering activities contrary to U.S. interests that occur within a specific geographic area.

Foreign Direct Product Rule applications for any given year refer to all entities to which an FDPR was applied. It includes both (1) entities that had an FDPR applied at the time of their listing in the specified year, and (2) entities that were initially placed on the Entity List in a previous year but received an FDPR in the specified year.

Although the Departments of State and Treasury coordinate closely on sanctions policy and implementation and each have their own sanctions authorities, this report did not make a distinction between the two for analytic purposes. Regardless of which agency has the authority, any sanctions that resulted in persons being put on the SDN List were included in this analysis. Any sanctions that did not result in placement on the SDN List were not included.

Since the publication of the 2023 Year in Review, EES has identified and corrected a few instances of data missing or being entered incorrectly. Additionally, EES has updated its methodology for attributing the nationality of individuals on the SDN List. As a result, some of the figures for 2022 and 2023 published in this report differ from what was published in the 2023 Year in Review.

Where possible, the report notes if a sanctioned entity has made a public statement or response to its designation on one of the sanctions lists. The authors were unable to find a comment from Gazprombank in response to its placement on the SDN List in November 2024.

For the first time, EES is publishing the complete dataset of 2023 and 2024 entity listings and SDN designations used in the analysis of the report. Click below to explore the full dataset.

For the SDN and Entity List datasets included with this report, the names, biographical information, addresses, and information identifying affiliations and business relationships included in the datasets are directly copied from Recent Action Notices published by the Treasury Department’s Office of Foreign Assets Control and by Federal Register Notices from the Bureau of Industry and Security of the Commerce Department. For more details about how the authors coded sanctions and export controls in the dataset, see the “Metadata” tabs. For more details on the methodology used to code the “Reason” columns in the Entity List dataset, please see the “Explanations” tab for a nonexhaustive clarification of terms.

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 Emily Kilcrease, Energy, Economics, and Security Program (EES) senior fellow and director, and John Hughes, EES adjunct senior fellow, for their reviews of this report. This report was made possible with general support to CNAS.

As a research and policy institution committed to the highest standards of organizational, intellectual, and personal integrity, CNAS maintains strict intellectual independence and sole editorial direction and control over its ideas, projects, publications, events, and other research activities. CNAS does not take institutional positions on policy issues and the content of CNAS publications reflects the views of their authors alone. In keeping with its mission and values, CNAS does not engage in lobbying activity and complies fully with all applicable federal, state, and local laws. CNAS will not engage in any representational activities or advocacy on behalf of any entities or interests and, to the extent that the Center accepts funding from non-U.S. sources, its activities will be limited to bona fide scholastic, academic, and research-related activities, consistent with applicable federal law. The Center publicly acknowledges on its website annually all donors who contribute.

About the Authors

Eleanor Hume is a research assistant for the Energy, Economics, and Security Program at CNAS. She supports the Center’s work on American economic statecraft and geoeconomic competition between the United States and China. Before joining CNAS, Hume was a policy analyst at the China Economic and Strategy Initiative, part of the Project 2049 Institute. She has also worked at the German Marshall Fund and on Capitol Hill.

Hume graduated from George Washington University with bachelor’s degrees in international affairs and Asian studies. She also holds a master’s degree in law and diplomacy from Tufts University. Hume is proficient in Mandarin and lived in China for nearly two years.

Kyle Rutter is a Joseph S. Nye, Jr. intern for the Energy, Economics, and Security Program at the Center for a New American Security. Rutter graduated cum laude from Florida State University (FSU) with a double major in international affairs and economics. As one of FSU’s Sustainability Fellows, he researched for and worked with the Florida Department of Environmental Protection on a statewide project to implement recycling programs for local and state government agencies. He also interned at the U.S. Department of State’s Office of China Coordination, researching emerging technology threats, Belt and Road Initiative projects, and human rights issues. Rutter is pursuing a master’s degree in security policy studies at George Washington University’s Elliott School, with a concentration in transnational security. His specific research interests include economic security, climate change and environmental sustainability, and U.S.–East Asian relations.