Think Tank Data Shows Uptick in SDN, Entity Listings Last Year
The U.S. added more people and entities to sanctions and export control lists in 2024 than the previous year, with a large portion targeting Russia and China, the Center for a New American Security said this week.
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CNAS said the Treasury Department saw a 25% increase in additions to its Specially Designated Nationals List, and the Commerce Department oversaw an 11% increase in parties added to its Entity List. Russia was the “primary target” of new SDN listings, while China was hit with the most entity-based export controls.
In total, the Biden administration added 3,135 people and entities to the SDN List in 2024, a “notable increase” from the 2,502 parties added in 2023. CNAS said 1,706 of those designations targeted Russian persons, and just five other countries received more than 100 designations, including China.
Commerce added 520 persons to the Entity List in 2024 -- an uptick from the 470 who were added in 2023 -- and just over half were based in China. CNAS said the number of Chinese persons added to the Entity List on a yearly basis exceeded the number of Russian persons for the first time since Russia invaded Ukraine in 2022.
The think tank noted that the U.S. use of sanctions “may shift in some notable ways” under President Donald Trump's administration, which has “clearly indicated” a preference for tariffs. “Tariffs may be used alongside or even instead of sanctions,” CNAS said.
It also said the U.S. could see a change in its approach to Russia sanctions as Trump tries to help negotiate a peace deal with Ukraine, and sanctions attention will instead likely turn to Iran and possibly China and North Korea.