U.S. President Donald Trump has long had a unique relationship with the use of sanctions, Washington’s most popular geoeconomic instrument. Less understood is that Trump’s approach in his second term has also differed sharply from his first. And the result has been a weakening of sanctions as a tool of U.S. foreign policy going forward.
Trump’s 2024 election campaign saw him repeatedly criticize sanctions, telling Bloomberg that sanctions were “forcing everyone away from us.” In a September 2024 speech to the Economic Club of New York, Trump declared that sanctions should be used “judiciously” and “as little as possible,” acknowledging that while “I was a user of sanctions … I put them on and take them off as quickly as possible” and warning that their continued expansion ultimately “kills the dollar.”
U.S. President Donald Trump has long had a unique relationship with the use of sanctions, Washington’s most popular geoeconomic instrument. Less understood is that Trump’s approach in his second term has also differed sharply from his first. And the result has been a weakening of sanctions as a tool of U.S. foreign policy going forward.
Trump’s 2024 election campaign saw him repeatedly criticize sanctions, telling Bloomberg that sanctions were “forcing everyone away from us.” In a September 2024 speech to the Economic Club of New York, Trump declared that sanctions should be used “judiciously” and “as little as possible,” acknowledging that while “I was a user of sanctions … I put them on and take them off as quickly as possible” and warning that their continued expansion ultimately “kills the dollar.”
Indeed, in his second term, Trump has demonstrated a willingness to lift sanctions, albeit only after he perceives that U.S. geopolitical and economic interests have been secured. Despite the failure of the U.S. memorandum of understanding with Iran, it should have been little surprise that Trump was willing to rapidly concede on sanctions in exchange for a deal with Tehran—even as doing so evoked opprobrium from some of his most steadfast allies and advocacy groups, for example the Foundation for Defense of Democracies (FDD), labelled the decision to do so as giving “Iran the ability to fund its rearmament without any oversight by the United States.”
During the first foreign visit of his second administration, Trump announced in Riyadh last May that he would lift sanctions on Syria, with the main U.S. sanctions authority—the Office of Foreign Assets Control (OFAC)—subsequently issuing a wide-ranging license suspending many thereof. At the end of last June, Trump signed an executive order revoking the six previous such orders that had underpinned the Syria sanctions regime and removed hundreds of Syrian individuals and entities from its blacklist. He pushed Congress to repeal the last remaining major sanctions law—the Caesar Syria Civilian Protection Act, which he himself had signed into law in 2019—which it duly did.
The most prominent example of Trump’s easing of sanctions has been Venezuela, which has seen sanctions lifted rapidly since the United States detained the country’s then-de facto president, Nicolás Maduro, in January. OFAC has issued more than a dozen general licenses since enabling U.S. firms to operate in Venezuela and allowing the Venezuelan regime under Maduro’s erstwhile vice president, Delcy Rodríguez, to access external services. At the beginning of April, sanctions on Rodríguez, whom the United States now formally recognizes as president, were also lifted. However, numerous other high-ranking Venezuelan officials remain under sanctions, including Interior Minister Diosdado Cabello, for whom the United States also nominally still has a $25 million bounty despite his repeatedly meeting U.S. officials in recent months.
The Venezuelan regime may have changed at the top, but the rest of its political hierarchy remains in place, albeit with a newfound loyalty to Trump and by extension the United States. But Trump’s action sets a dangerous precedent in Venezuela because it undermines the policing and enforcing of sanctions. The failure to lift sanctions before such engagement leaves questions about their enforcement that could enable more willingness to engage and less scrutiny by third parties on other sanctioned individuals.
The politicization of sanctions both at home and abroad matters. As Trump referred to in his 2024 campaign, there is a direct correlation between the power of the U.S. dollar and the use of sanctions. The effectiveness of extraterritorial application of U.S. sanctions—the reason that businesses outside the United States largely comply with them in all but the most frontier jurisdictions, even as Russian, Chinese, and even European sanctions are brushed off—is because of the reach of the dollar. All recent presidents have been willing to impose secondary sanctions on non-U.S. entities for noncompliance because of the view that their use of the dollar makes U.S. jurisdiction applicable. And few businesses can survive without access to the dollar system. For example, in February, a Swiss bank accused of violating U.S. sanctions was shut down in a day after Washington threatened to cut off its access over its sanctions violations, despite theretofore having fought off its domestic regulators effectively over the matter.
It is not Trump’s willingness to lift sanctions that creates this risk but rather his uneven application of them—both in terms of lifting and imposing them.
The case of Cabello is just one such example. Iran potentially serves as another. Again, whether one agrees with FDD’s public advocacy of war against Iran or not, the group was right to point out that the since-withdrawn general license for trading in Iranian oil that followed the June MOU appeared to violate the U.S. law giving Congress a say on future agreements with Tehran. That matters for legislation pertaining to Russia sanctions, too, in particular the 2017 Countering America’s Adversaries Through Sanctions Act (CAATSA), which sought to ensure that a president could not wholesale lift sanctions on the Kremlin without addressing its aggression against Ukraine.
But while Trump has proved willing to expand sanctions against Russia and appears to be warming toward Kyiv, this is a live concern. While the Trump administration’s blacklisting of Russia’s two largest oil firms, Rosneft and Lukoil, last October was the move that most tightened the screws on the Kremlin since 2023, it has dropped the ball on the second-most significant such move, namely the U.S. imposition of secondary sanctions on entities linked to Russia’s Arctic 2 liquefied natural gas project upon its first shipments in August-September 2024.
That October, the Oxford Institute for Energy Studies described the imposition of these sanctions as a litmus test for the efficacy of sanctions against Russin LNG and the ability of the United States to constrain Russia’s largest growth driver. And the move was effective—LNG cargo from Arctic 2 was unable to find a buyer for months, until China’s Beihai import terminal became the first to do so shortly after Trump hosted Russian President Vladimir Putin in Alaska in August 2025. Washington has failed to impose additional secondary sanctions since, even after Beihai began to import LNG from other sanctioned Russian LNG projects late last year. Last month, Reuters reported that Beijing was planning to expand the sites for accepting sanctioned Russian LNG. With Qatar’s own gas exports trapped by the crisis in the Strait of Hormuz and driving global gas prices to post-2023 highs, this trade has greatly benefited Russia and undermined the U.S. secondary sanctions threat.
Domestically, Trump’s approach to applications also risks undermining their effectiveness. Trump has shifted from using sanctions authorizations’ for their stated purpose. For example, the Global Magnitsky Act sanctions that was designed to target kleptocrats and human rights abusers was used last July to blacklist Brazilian Supreme Court Judge Alexander de Moraes—and his wife—over former President Jair Bolsonaro’s trial before the White House reversed itself in December. Further examples of gratuitous designations abound, including that of Colombian President Gustavo Petro under an executive order targeting those involved in the illicit drug trade—though Trump nevertheless subsequently hosted him at the White House—the first individual on a U.S. sanctions blacklist ever to receive that honor. Petro is currently lobbying for his removal before he leaves office on Aug. 7.
Shortly after taking office, the Trump administration issued a national emergency declaration under the International Emergency Economic Powers Act (IEEPA), the legislation that underpins most modern sanctions regimes, to blacklist a series of International Criminal Court officials over their indictments of Israeli government representatives in relation to the war in Gaza.
Last July, the same executive order was used to sanction Francesca Albanese, the lightning-rod U.N. special rapporteur on human rights in the occupied Palestinian territories, who has become a bugbear of Israel and its allies over her perceived advocacy.
But Albanese pushed back, with her husband and daughter suing the Trump administration over her designation. On May 13, Judge Richard Leon issued a preliminary injunction, ordering the first-ever suspension of an OFAC blacklist designation on First Amendment Grounds. Leon’s injunction did not find that Trump’s power to sanction Albanese was constrained by the IEEPA but instead rested on the argument that her blacklisting was due to her political speech. That Albanese is an Italian resident in Tunisia did not matter—her extensive U.S. connections, property in Washington, and U.S. citizen daughter sufficed.
The Trump administration swiftly secured an administrative stay of Leon’s judgment, however, allowing OFAC to resanction Albanese. The case will now go to appeal. While defenders of Albanese and critics of Israel are sure to be watching, so too will kleptocrats, dictators, and oligarchs, who will be hoping the case finally results in precedent for them to pursue their own future legal challenges to U.S. sanctions designations.
The Trump Administration also complied with the only other court-ordered suspension of such a designation, de-listing Tornado Cash, a “crypto-mixer” that seeks to obfuscate the origins of crypto holdings, in line with a November 2024 appeals court ruling that found IEEPA does not cover “smart contracts.” The appeal was funded by crypto platform Coinbase, which has made extensive political donations to Trump in an effort to “maintain good relations” with a White House that dropped a major lawsuit against the firm a month after taking office. The Trump administration has not appealed the Tornado Cash ruling, nor has it backed legislation that would plug the loophole despite its clear risk implications for combatting money laundering.
Sanctions are a powerful tool. Much attention has been paid in recent years to whether they are effective at achieving foreign-policy goals and what the costs associated with imposing them are. Those debates should continue—they improve U.S. policymaking. So too should debates about the wisdom of individual sanctions programs. But the blunting of the tool itself, both before U.S. courts and on the international stage, is a policy outcome that all should strive to avoid.
