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US More Than Doubled SDN Additions From 2021 to 2022, Think Tank Says

The Office of Foreign Assets Control added 2,275 parties to its Specially Designated Nationals List last year, more than double the number it added to the list in 2021, the Center for a New American Security said in its Sanctions by the Numbers blog last week. The think tank said sanctions against Russia in response to the country’s invasion of Ukraine accounted for 1,698 of the 2,275 total designations. The remaining 577 additions to the SDN List would have been “comparable” to past years, adding that “significant” changes in the number of designations from one year to the next is “usually due to current events rather than changes in the underlying sanctions policy.”

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The rise in designations last year shows that the tool continues to be one of the U.S. government’s “policy tools of choice,” CNAS said. The think tank said it’s “almost certain that sanctions and export controls” will continue their major role in American foreign policy throughout 2023, including by “maintaining and possibly expanding Russia sanctions and export controls, potentially restricting Russian assets held abroad, and focusing on Russian evasion tactics.”

Former officials and sanctions lawyers warned that the uptick in new designations risks straining already limited resources at the Treasury Department, including the agency’s efforts to remove parties from the SDN List (see 2305010023).