If the US stops policing sanctions, can anyone else fill that role?

The enforcement of international sanctions comes in many forms.

It can be as dramatic as French commandos intercepting a sanctioned Russian vessel at sea, or as political as Washington’s recent decision to sanction Cuban President Miguel Díaz-Canel and members of the Castro family. It can also be highly technical, such as when regulators penalize a bank for failing to identify a sanctioned Russian official because his name was spelled differently.

“The keys to effective sanctions are design, implementation, and – critically – enforcement to ensure the restrictions are viewed as credible,” says Tom Keatinge, director of the Centre for Finance and Security at the Royal United Services Institute in London.

Why We Wrote This

A sanctions regime is only as good as its enforcement, experts say. With the United States showing erratic commitment to sanctioning Russia, among others, questions have emerged about whether the line can be held without Washington.

And whatever the particular method, experts concur: Without enforcement, sanctions are little more than symbolic gestures.

That is why the recent unpredictability of the United States with regard to sanctions – in particular toward Russia , but also regarding Iran, Venezuela, and Cuba, among others – has raised eyebrows among the powers upholding such regimes in the West. And it highlights the critical role that the U.S. plays within sanctions enforcement, and the difficulty that other parties that want to push sanctions would have if the Trump administration decides to reverse course and abandon its role as the foremost global sanctions police officer.

“The shift in sanctions focus by the United States poses challenges for both governments in Europe and the private sector globally,” says Mr. Keatinge. “Sanctions work best when countries are aligned, as this reduces loopholes and facilitates consistent implementation by the private sector. The varied action of the U.S. blunts this need for and benefit from alignment.”

Norlys Perez/Reuters

Cuban President Miguel Díaz-Canel attends a government rally called by Cuban authorities to protest U.S. policies toward the island, including the indictment of the former president, in Havana, May 22, 2026.

The major players

Modern sanctions enforcement is a complex and resource-intensive challenge. Last year alone, the United States, European Union, United Kingdom, and United Nations – the four major players in global sanctions – issued 265 sanctions-list updates and added nearly 4,000 new designations, according to LexisNexis analysis. Russia remained the focal point, while Iran again faced sanctions over its nuclear program.

Each new sanctions package issued by one of the four triggers a cascade of compliance obligations for financial institutions, shipping companies, insurers, exporters, and other businesses. Those parties must constantly monitor changes to ensure they are not dealing with sanctioned parties. A single listing can instantly freeze assets, prohibit transactions, and expose companies to serious fines.

The challenge of keeping pace is compounded by a fragmented global sanctions landscape and uneven enforcement capacity. In the United States, sanctions enforcement is largely centralized around the Treasury Department’s Office of Foreign Assets Control, which administers more than 30 sanctions programs and is staffed by several hundred officials. In Britain, the Office of Financial Sanctions Implementation has grown to over 130 full-time staff members since Russia’s invasion of Ukraine.

In the EU, while sanctions are agreed collectively in Brussels, enforcement remains largely the responsibility of national authorities, whose resources and expertise vary wildly. The European Commission has sought to narrow those disparities, however, by setting minimum enforcement standards and strengthening coordination.

“The EU is constantly breaking taboos with each new sanctions package,” said Mihkel Märtens, a sanctions officer at the Ministry of Foreign Affairs in Estonia, during an online conference organized by the Center of European Policy Analysis. “If you would have asked anyone working in EU sanctions five years ago whether the EU would start adopting anything that remotely resembles secondary sanctions, they would have just laughed.”

“The only truly feared sanctions agency”

Still, while Europe is widely seen as more dynamic than in the past, it can too easily be circumvented by Russia, says Mr. Keatinge. “Despite an increase in enforcement action in Europe, the United States OFAC remains the only truly feared sanctions agency.”

Experts say that’s largely because of the magnitude of U.S. enforcement. Amir Fadavi, CEO of Sanctrust, which provides advice on sanctions compliance, says the watershed moment came in 2014, when French bank BNP Paribas agreed to pay nearly $9 billion to settle allegations that it had violated U.S. sanctions. That penalty sent a clear message that even non-U.S. institutions could face s…