Targeted sanctions have become a major part of how the U.S. government communicates with the world and signals its foreign policy. These measures, which range from financial sanctions to visa bans, are imposed against specific individuals, companies, or organizations rather than entire countries.
Although they have had major blind spots, previous administrations have used these sanctions to spotlight abuses of power and offer a measure of accountability where impunity has prevailed. By imposing reputational and financial costs, sanctions helped alter the behavior of abusive Bangladeshi security forces, stigmatized corrupt businessmen in the Democratic Republic of the Congo, supported activists seeking deeper anti-corruption reforms in Ukraine, and raised the profile of political prisoners in Russia.
The signals the second Trump administration is sending with its use of certain sanctions, however, are quite different. Some messages have been clear, such as its contempt for the rule of law, evident in its targeting of judges on the International Criminal Court. But other times, the Trump administration’s motivations have been more difficult to parse, even for those who follow sanctions policy closely. That includes the growing body of existing sanctions that the administration has quietly lifted with little or no explanation, often to the benefit of corrupt and well-connected figures or allies. As a recent NPR report found, some sanctions targets have been granted relief “despite a lack of clear evidence of change in their behavior” and in ways that do not seem to advance clear national security or anti-corruption goals.
Individually, any one of these removals from the Treasury Department’s sanctions list or other similar programs may have a legitimate reason beneath the surface. Taken together, they form a growing pattern that gives cause for alarm about whose interest these policy changes are serving – especially when the sanctions relief touches on areas where the administration’s record outside the sanctions context is alarming in its own right.
Congress needs to do much more oversight in this area, looking carefully at who the Trump administration is removing from the sanctions list and why. From the outside, it appears that the administration is hollowing out the sanctions program for human rights abuse and corruption, rehabilitating corrupt or well-connected friends, and quietly inching back sanctions on Russian-linked actors, and obscuring its moves behind the opaque procedures and technical language of sanctions relief.
Good Reasons for Lifting Sanctions, and Murky Ones
Many of the Trump administration’s sanctions removals have broadly made sense. After Syrian dictator Bashar al-Assad was overthrown in December 2024, Congress and the Trump administration heeded calls from human rights defenders to lift a wide range of sanctions and help the country begin a new era. While there are reasons to criticize the administration’s rapprochement with Belarus, the White House has clearly extracted real concessions in exchange for lifting certain sanctions there, including the release of Belarusian political prisoners.
Of course, sanctions are not meant to stay in place forever. Individuals who are targeted must be able to challenge the basis for the sanctions, because conditions change and governments make mistakes. The prospect of sanctions relief can also serve to incentivize behavior change from the target or those around them.
Often, though, sanctions that are imposed with an announcement from a high-ranking official and a description of the actions being condemned are later lifted quietly. Even though the public may have an interest in understanding what has changed, the Treasury Department may simply note that a person has been removed (or “delisted”) from sanctions in a longer and more technical press release describing unrelated actions.
The opaqueness of the sanctions delisting process is not unique to Trump. For example, the Biden administration may have had a good reason in 2024 to quietly act on a petition to delist a Dominican businessman who had been sanctioned for corruption seven years earlier, although we do not know what it was.
In rare cases, though, the opaque and discretionary nature of the removals process has clearly enabled abuse. The first Trump administration tried to secretly give sanctions relief to Dan Gertler, an allegedly corrupt Israeli billionaire operating in the Congo who had mobilized several administration allies to lobby on his behalf to have his sanctions lifted. Even former Trump administration appointees called the action “shocking…an abuse of the process” and “truly appalling,” and Biden appointees reversed it a few weeks later.
Now the second Trump administration’s delistings are attracting concern, both for their sheer volume and for their substance.
In a new tracker, we at Human Rights First found that, as of mid-April, at least 145 individuals or companies appear to have had Treasury Department sanctions against them lifted under this administration, in addition to a handful of similar State Department visa bans and U.S. Customs import restrictions. By our calculations, the Treasury actions are on a pace that greatly exceeds the number of comparable delistings in the Biden administration, which were just under 200 over the course of a four-year term. (We are omitting from these counts delistings that happened through the ending of an entire sanctions program, such as with Syria or the West Bank, or delistings in the narcotics or terrorism programs.)
Moreover, many of the Trump delistings relate to topics for which this administration has built up an alarming record outside the context of sanctions. These include its pause of Foreign Corrupt Practices Act enforcement, its pardons of corruption defendants, and its broader posture toward Russia and Ukraine. These and other actions raise concern that an unexplained delisting could signal deeper policy reversals taking place under the cover of a process that is hard to scrutinize. Our tracker points to three worrying trends: the silencing of the Global Magnitsky sanctions program, the rehabilitation of corrupt friends and allies, and a steady drumbeat of relief for Russia-linked actors.
The Withering of Global Magnitsky
First, the Trump administration has largely silenced the Global Magnitsky sanctions program. Launched in 2017 with a bipartisan mandate from Congress, this program made it possible to financially sanction corrupt or abusive actors anywhere in the world and ban their entry into the United States. Because of the directive that the executive branch consider input from civil society groups in implementing the program, activists have often sought Magnitsky sanctions as a tool for accountability when other forms of justice are unavailable to them. The program has inspired similar types of sanctions in other countries.
The current administration gave lip service early on to implementing Global Magnitsky, but the basic numbers reveal where the program stands: the first Trump administration sanctioned 101 targets in the program’s first year; the tally in President Joe Biden’s first year was 173; and the second Trump term has seen only six Magnitsky targets in its first 16 months. Worse yet, three of those actions targeted a Brazilian Supreme Court Justice in a widely condemned action that was reversed a few months later.
Indeed, this administration has lifted more Global Magnitsky sanctions than it has imposed. A senior Hungarian official and a former Paraguayan president – both sanctioned for corruption and linked to conservative governments friendly to the Trump administration – were delisted last year with vague justifications about how the sanctions were “inconsistent with U.S. foreign policy interests” or “no longer required to incentivize changes in behavior.” The delistings were also made without the advance notice and specific justification to Congress required for this program.
These precedents inspired other sanctioned persons to seek similar relief, though not via reform or accountability. Some have tried pandering to the administration, such as when Bulgaria briefly joined President Trump’s “Board of Peace” to try to get a senior politician delisted. South Sudan, for its part, offered to abet U.S. human rights violations, seeking sanctions relief for a former top official in exchange for arbitrarily detaining migrants whom the United States wanted to deport to third countries where they have no connection.
The lobbying for these delistings has not paid off, at least not yet. But corrupt actors and human rights abusers clearly see reason to think this administration is open for business in this area, and not particular about the terms.
Fortunately, other jurisdictions with Magnitsky-style sanctions programs have not followed the United States’ lead. After the Trump administration canceled a program under which Israeli settlers had been sanctioned for attacking or dispossessing Palestinians in the West Bank, the United Kingdom and several other governments instead went further and sanctioned two senior Israeli ministers for their role in inciting such violence. But this kind of attempt to fill the gaps the Trump administration is leaving and to counter its signals of impunity has been rare.
Unraveling Accountability for Corruption and the Well-Connected
Second, by lifting sanctions under other programs off of certain individuals and companies, the administration appears to be carrying out a growing rehabilitation of the corrupt or the well-connected.
A wide-ranging group is benefiting. A Lebanese businessman sanctioned in 2021 for “personally profiting from…pervasive corruption” was delisted in February with no explanation. A Dominican company that was found to be engaged in forced labor practices, and whose owners include American donors with fundraising ties to Trump, was allowed last spring to resume importing sugar without taking key remediation steps. A famously corrupt leader from Equatorial Guinea had corruption-related travel restrictions loosened last fall, and a former Kenyan official claims to have as well. A top Bosnian Serb politician sanctioned for corruption was delisted after Trump allies intervened on his behalf.
Part of the context for these actions is the administration’s broader rollback of an anti-corruption agenda at home and abroad. This backdrop makes it easy to see sanctions relief measures like these as being adjacent to the administration’s efforts to gratify friends and political allies with pardons – or at least, reasonable to withhold the benefit of the doubt when the administration tries to downplay these delistings as mere administrative steps.
In another set of delistings, the Treasury Department last July removed sanctions against eight individuals and companies that had been targeted for arming, trading with, or otherwise having links to the brutal military government of Myanmar. This announcement came shortly after the junta’s leader praised Trump and called for sanctions relief. A United Nations expert on human rights in Myanmar condemned the administration’s decision, calling it “a shocking turn in U.S. policy” and “a major step backward for international efforts to save lives by restricting the murderous junta’s access to weapons.”
White House officials insisted the delistings “were not indicative of a broader shift in U.S. policy” toward Myanmar. One prominent sanctions lawyer volunteered that three of the delisted persons were his clients, and that they had provided evidence to justify their delisting through the administrative petition process. For them and the others delisted, though, it is unclear what behavior they might have changed; the Treasury Department “declined to say why” any of the delistings happened. As similar cases emerge, it is difficult to simply trust the judgment of U.S. government agencies.
Relief for Russian Networks
Finally, Trump’s affinity with Russian President Vladimir Putin and his desire to do business with Russia may also be finding expression in sanctions delistings, some of which could be seen as softening the ground for a broader, more consequential rollback of U.S. sanctions related to Russia.
More than in any other area, the administration has been producing a steady stream of sanctions removals on Russia-related targets, starting late last fall and reaching a weekly drumbeat in March. Most of these sanctions had been intended in one way or another to hamper the Russian economy as the country continues its war against Ukraine. The delistings come even as Trump’s allies claim he is open to increasing pressure on the Putin regime.
Again, some of these delistings may have a reasonable explanation. One Russian legislator who was delisted died several years ago. Some other individuals delisted had been sanctioned simply for being officials at a state-owned Russian company or Russian bank, a status that they may well have changed. Some of the broader sanctions relief was at least ostensibly put in place to mitigate the economic shocks of the United States’ illegal war on Iran.
But some of these unexplained delistings raise more serious questions: a Cypriot financial adviser reported to be a personal fixer for the Russian billionaire Alisher Usmanov, three Malian military officials who allegedly facilitated the abuses committed by Russia’s Wagner Group in that country, a Turkish businessman involved in “enabling Russian intelligence services to procure technology for sanctioned Russian entities,” and a Hungarian bank executive who has reportedly coordinated with Russian officials to expand Russian influence and intelligence presence in Europe.
In theory, of course, these actors might all have cut ties with Russian authorities or changed their behavior. Reports about the administration’s desire to resume business with Russia at any cost, however, give reason to be more cynical. So do Trump’s manifest sympathies for Russia over Ukraine, and reports that Russian authorities are working at high levels to secure the delisting of their fellow nationals – including working closely with Hungary to lift EU sanctions on people tied to Usmanov.
The Trump administration might justify some of its sanctions relief as facilitating dialogue and diplomacy between the United States and Russia, as was the case with a Russian delegation whose sanctions were waived to allow a visit to Washington in March. But if diplomacy is the administration’s motivation here, it has not had the courage to lay out the approach and defend it.
Explain Yourself, and Say What You Want
Imposing or removing sanctions can speak powerfully. The Trump administration’s actions described here, though, suggest a preference for sending muffled and distorted signals instead, lest the public at home or abroad fully understand them.
Given the rapid rate at which the administration has been lifting these sanctions, Congress should demand clarity. It should hold hearings to force the administration to speak on the record about its actions. Some Democratic senators have objected to specific sanctions removals, but illuminating the broader picture is as important as trying to shine a light on individual cases. This should include asking how many delistings have not been publicly reported under State Department visa bans that can be imposed and lifted confidentially.
A future Congress will need to legislate more effective requirements for delisting transparency. Some such rules are already in place, including in the Global Magnitsky Act, but this administration is clearly comfortable ignoring them. The primary law for U.S. financial sanctions should be amended to require a substantive explanation for any delisting, one that would generally be made public, or submitted confidentially to Congress only if necessary for the safety of an individual involved.
Future administrations should also make clearer when they impose a given sanction what it is for, and indicate – as the Treasury and State Department rarely do – what actions they are looking to see that would prompt them to lift the sanction. Doing so would help incentivize behavior change by setting clear expectations. Articulating the requirements for sanctions relief would also serve as a soft check on future administrations that might be tempted to lift the sanction on unclear, unrelated, or otherwise dubious grounds.
Targeted sanctions are imperfect but useful tools for protecting human rights and fighting corruption. They must not become part of the landscape of impunity that they were meant to challenge.
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Author’s Note: Thanks to Human Rights First Legal Fellow Justin Roberts for research and support for this article.
