I. Introduction
For over a decade, the U.S. Department of the Treasury ("Treasury") has administered economic sanctions in response to the national emergency, first declared by President Clinton and renewed and expanded by President Bush, caused by the policies and actions of the Government of Sudan (the "GOS"). These include the GOS's support for international terrorism, efforts to destabilize neighboring governments, and perpetration and sponsorship of pervasive human rights violations in South Sudan and, more recently, in the Darfur region. The precise impacts of any sanctions program are difficult to isolate and quantify. Nevertheless, Treasury assesses that financial sanctions have had a marked effect on the decision-making of the GOS, and have provided useful leverage to advance U.S. foreign policy in Sudan. Treasury also assesses that U.S. sanctions are being implemented with great fidelity by the U.S. private sector, by non-U.S. companies, and beyond our borders.
It should be remembered that a sanctions program is but one part of a larger foreign policy toolkit, and any assessment of the effectiveness of sanctions must consider the sanctions in their proper role as an instrument of foreign policy, not as the complete expression of that policy.
Congressional Reporting Requirement
The Sudan Accountability and Divestment Act of 2007 (the "SADA"), Pub. L. No. 110-174, section 10(b), requires the Secretary of the Treasury to provide a report "assessing the effectiveness of sanctions imposed with respect to Sudan" under the International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. =A7=A7 1701-1706. This report benefited from consultations with the State Department, the Commerce Department, the U.S. Agency for International Development, other concerned agencies, and relevant senior U.S. government officials.
In accordance with the reporting requirements set forth in section 10(b) of the SADA, this report includes:
1. a description of each sanction imposed under a law or Executive order;
2. the name of the person subject to the sanction, if any; and
3. whether or not the person subject to the sanction is also subject to sanctions imposed by the United Nations.
More generally, this report takes a holistic approach to assessing the effectiveness of sanctions, moving beyond quantified accountings of blocked assets and disrupted transactions. The report does not address the possible costs of sanctions to the United States or U.S. persons. In addition, the discussion of sanctions in this report is limited to those sanctions imposed by Treasury under IEEPA and therefore does not include measures enforced by other Executive or state-level agencies, such as visa or export sanctions implemented by the State Department.