The Sanctions Regime: Economic Warfare by Other Means

The Treasury Department announced a new round of sanctions this week, bringing the total number of sanctioned entities to over 14,000. The United States now maintains economic restrictions against roughly one-third of the world's nations. This is not foreign policy. It is the fiscal architecture of empire.

What Happened

• The Treasury Department's Office of Foreign Assets Control (OFAC) designated 247 new entities across six countries
• Total active sanctions programs now number 38, covering approximately 60 nations
• The number of individually sanctioned entities exceeds 14,200, up from 912 in 2001
• Compliance costs for American financial institutions exceeded $41 billion in 2025

THE HISTORICAL ECHO

The British Empire maintained its commercial supremacy through the Navigation Acts, which restricted trade flows to benefit the imperial center. The mechanism was legal, not military: violators were not invaded but excluded from the financial system. The penalty for defiance was not conquest but commercial isolation.

The American sanctions regime operates on the same principle, updated for the age of electronic finance. Because the dollar clears through American correspondent banks, the United States possesses the ability to exclude any entity from the global financial system without firing a shot. This is not an incidental feature of American power. It is its most potent instrument.

THE INSTITUTIONAL CONTINUITY

Sanctions were once a tool of last resort, imposed after diplomacy failed and before military action began. They are now a tool of first resort, imposed reflexively and removed almost never. Of the 38 active sanctions programs, the oldest dates to 1979. The average duration is 17 years. Programs are added; they are not subtracted.

This ratchet effect is institutional, not ideological. OFAC's budget and staff grow with each new program. Congressional staff build expertise in sanctions administration. Think tanks produce sanctions policy papers. The apparatus generates its own demand.

THE MYTH BEING SOLD

Sanctions are presented as an alternative to war, a humanitarian instrument that punishes governments without harming populations. The evidence suggests otherwise. Studies of comprehensive sanctions programs show that civilian populations bear the primary cost while political elites develop workarounds through front companies and alternative financial networks. The pain is democratic; the evasion is aristocratic.

WHAT THIS ACTUALLY CHANGES

The new designations add to an already sprawling compliance burden without meaningfully altering the behavior of the targeted governments. The sanctions apparatus has become self-justifying: each new designation demonstrates activity, which justifies budget requests, which fund additional designations.

POLLERBULL SIGNAL

• What moves power: Sanctions policy is bipartisan in a way that reveals it is not truly political. Both parties support maximum pressure because the costs are borne by foreigners who do not vote in American elections.
• What is pure theater: The humanitarian exemptions that theoretically allow food and medicine but in practice deter banks from processing any transactions with sanctioned jurisdictions.
• What would actually matter: A credible alternative to the dollar-based clearing system. China's CIPS and Russia's SPFS are attempts, but neither has achieved the network effects necessary to compete.

SOURCES

• Treasury Department OFAC designations database
• Congressional Research Service, sanctions programs overview
• American Bankers Association, compliance cost survey 2025