Taking the Pulse of Major Sanctions Lists
The Calm Before the Storm
January – December 2021

LexisNexis® Risk Solutions analyzed sanctions data from core regulators the United Nations (UN), European Union (EU), Office of Foreign Assets
Control (OFAC), and Office of Financial Sanctions Implementation(OFSI) - over the course of 2021 to identify trends and changes in policy.
Data for the year shows continued sanctions activity in relation to terrorism –those programs triggered the highest number of updates consistently acrossregulators. However, we also observed a shifting focus on Belarus and Myanmar,as political developments led to spikes in sanctions activity.
On the thematic side, sanctions in relation to human rights violations
and corruption expanded further in 2021, notably through the implementationof new authorities in the EU (human rights) and the UK (corruption).
Overall, sanctions activity in 2021 was aligned with 2020. However,
we did start to see the “Biden Effect” on U.S. sanctions policy – net additions
fell by 75% compared to Trump’s final year in office.
At the time of publishing, we are witnessing unprecedented sanctions activity due
to ongoing hostilities directed toward Ukraine. The next edition of our Sanctions
Pulse Infographic will reflect the surge of activity we are seeing, and will include
data from January to June 2022.

Key Takeaways

211+517

Number of total updates to the UN,
EU, OFAC, OFSI lists

Net count of added designations
for the full year (vs +614 for 1H 2021)

The net decrease in the second half of the year was driven
by significant decreases in the OFAC list.

Number of List Updates per Agency 2021
Monthly Updates – 2021
35302520151050Jan.

Feb.

Mar.

Apr.

MayUN

Jun.

Jul.

Aug.

OFAC

Sep.

Oct.

EUNov.

Dec.

OFSI

2021 Overall Changes

6%

9.5%

20%

12%
39%

45.5%

74%

27%

51%

45%

61%
10%

UN

EU

Total 225

OFAC

Total 739

OFSI

Total 1,657

Added

Modified

Total 505

RemovedHighlights
There is a stark contrast between the activity of the UN and that of other agencies:
Changes to the UN list were relatively rare (25 updates) in 2021, which
decreased the net overall number of UN sanctioned persons and entities (-32).
This trend is consistent with what we’ve observed in recent years.
As expected, OFAC continued to be the most frequently updated list in 2021,
with 93 updates. Updates to the EU and OFSI lists were about half as frequentwith 45 and 48 updates, respectively.
Looking at the net change in designations, however, the EU list grew more in 2021(+266 designations) than the OFAC (+211) or OFSI (+72) lists.
Major international issues triggered significant sanctions activity:
In terms of country sanctions, the situation in Myanmar and in Belarus triggered
many sanctions responses by the U.S., the EU and the UK.
Looking at thematic sanctions, while terrorism remained very high on the politicalagenda, 2021 saw the continued expansion of human rights and global corruption
programs, with steady designations from the U.S. and the emergence of similar
sanctions programs in the EU and UK.

A Closer Look by Agency
UN

Activity:
225 designations
added, modified
or removed…

-32

through

resulting in

25
updates...

netchange ofdesignations

UN Updates: Scale and Nature of Changes
Designations changes

Number of list updates

100
8780

660

5440
3
220

100Jan.

Feb.

Mar.

Apr.

MayAdded

Jun.

Jul.

ModifiedAug.

Sep.

Oct.

Removed

Nov.

Dec.

Updates

UN Programs Triggering Updates
10Terrorism

6Iraq

3

Central Africa Rep.

2

Libya

2

Yemen

1

Somalia1

SudanHighlights
In 2021, the UN list updates were limited to seven programs. 13 new designations
were imposed under five programs only:
Terrorism sanctions (under ISIL/Al-Qaida): five new designations.
Somalia and Yemen sanctions: three new designations for each program.
Libya and Central African Republic: one new designation for each program.
The UN waived sanctions against 45 persons and entities:40 persons and entities previously designated under the Iraq Sanctions program,continuing a wider trend of easing sanctions on Iraq (28 removals in 2020).
Three under the ISIL/Al-Qaida Sanctions.
One target was removed from the Sudan sanctions and one from the Libyan sanctions.
The two spikes in activity in February and December correspond to periodic reviewsof designated persons by the UN Sanctions Committee on ISIL and Al-Qaida in orderto renew sanctions on these entities.

EUActivity:
739 designations added,
modified or removed...

+266

45
through

resulting inupdates...

net change of designations

EU Updates: Scale and Nature of Changes
Designations changes

Number of list updates

2009180

8160

7140

6120

5100
480

360

240

120
00Jan.

Feb.

Mar.

Apr.

May

AddedJun.

Jul.

ModifiedAug.

Sep.

Oct.

Removed

Nov.

Dec.

Updates

EU Programs Triggering Updates (Top 10)
9Terrorism

5Ukraine

7Iraq

4Myanmar

7

Libya

3

Global Human Rights

6Belarus

2

Central African Rep.

5Syria2

IranHighlights
We observed steady sanctions activity by the EU in 2021. New designations
were concentrated during the first half of the year and were primarily focusedon the following countries and thematics:
Belarus, with six updates in 2021, was the program that saw the most addeddesignations. The most significant round of designations occurred on June 21stwhen 85 persons and entities were sanctioned, following the unlawful forced
landing of an intra-EU Ryanair flight.
Myanmar/Burma sanctions, with 35 new designations through four updates.
Whereas terrorism remained high on the sanctions agenda with nine updates,
2021 also saw the first EU sanctions imposed under the global human rights program.
Three updates were made, resulting in sanctions against 22 persons and entities.
The EU waived sanctions against 70 persons and entities, primarily in relation
to the Iraq sanctions, following suit with the UN.
The remainder of activity largely consisted of limited changes or amendments
to existing programs. Libya is a good example: of seven updates in total, only two
designations were added while five targets were removed and one was updated.

OFAC
Activity:
1,657 designations added,
modified or removed…

+211

93
through

resulting inupdates...

net change of designations

OFAC Updates: Scale & Nature of Changes
Designations changes

Number of list updates

600

14

12500

10

400

8300
6200

4100

200Jan.

Feb.

Mar.

Apr.

Added

MayJun.

Jul.

ModifiedAug.

Sep.

Oct.

RemovedNov.

Dec.

Updates

OFAC Programs Triggering Updates (Top 10)
27

Terrorism

8

China

21

Human Rights& Corruption

7

Russia15

Narcotics

7

WMD
Proliferation

13

Iran

5

Yemen

11

Burma/Myanmar

5

Syria

Highlights
We observed very frequent changes to the OFAC list in 2021, with 93 updates. Three thematic
programs accounted for more than half of all updates recorded: terrorism, global humanrights and corruption, and narcotics trafficking. Country programs that were most frequently
updated include Iran, Myanmar, China, and Russia.
New designations occurred fairly consistently across the year, with spikes in Juneand December:June designations included:
The largest set of designations to date under the Global Magnitsky sanctions program,targeting a Bulgarian network of corruption.
A set of “Chinese Military-Industrial Complex” companies (CMIC) subject to an
investment ban.
Persons and entities in Belarus.
December designations resulted primarily from numerous updates under the Global
Magnitsky sanctions programs adding about a hundred persons and entities fromvarious countries across the globe
Finally, the 2021 sanctions program targeting “Specified Harmful Foreign activitiesof the Government of the Russian Federation” triggered an extensive numberof designations related to Russia.
A rather unusual pattern was observed towards the end of the year, with OFAC
waiving sanctions against a significant number of persons and entities
listed under counter narcotics authorities. This coincided with two developments:
The publication in October 2021 of the Treasury Sanctions Review, which in part looked
into the “potential operational, structural, and procedural changes to improve Treasury’s
ability to use sanctions.”
The decision to remove the Terrorist Designations of the “Revolutionary Armed Forcesof Colombia (FARC).” A number of persons and entities removed from the OFAC list
in December 2021 were located in Colombia and/or connected to the FARC.
These removals resulted in a net decrease in the size of the OFAC list during the second
half of 2022.

OFSI (UK)

Activity:
505 designations
added, modifiedor removed

through

resulting in26

+72

updates...

net changeof designations

OFSI Updates: Scale and Nature of Changes
Designations changes

Number of list updates

250

87200
65150

4100

3250
100Jan.

Feb.

Mar.

Apr.

MayJun.

Jul.

Aug.

Sep.

OFSI Programs Triggering Updates

Added

Modified

Removed

Oct.

Nov.

Dec.

Updates

OFSI Programs Triggering Updates (Top 10)
13

Terrorism

6

Russia10

Belarus

6Iraq

8

GlobalHuman Rights& Corruption

6Syria

5

Yemen

6

Libya

4

ChemicalWeapons

6

MyanmarHighlights
As of January 1, 2021, the UK became entirely autonomous from the EU in implementing its
sanctions policy. The transition had been thoroughly planned, with the UK passing legislation
to continue the effect of most existing EU acts.
The year started with significant amendments, but no added designations in January.
Updates focused on:
Deletions: to reflect UN decisions or to adjust the scope of the OFSI listed entities (i.e.,removing North Korean vessels).
Amendments: to provide additional background information on the reasons of listing,which resulted in a spike of modified records in February.
Autonomous designations kicked in in February:
The first round of OFSI designations in 2021 occurred on February 1st, with four individuals
added under the Zimbabwe regime (as of the end of 2021, these individuals are still absent
from the EU list).
The bulk of new designations in February was related to Belarus with sanctions being
imposed against 27 individuals.
2021 also saw the introduction of a new sanctions regime in the UK targeting globalcorruption. Combined with the existing human rights sanctions, these two regimes
contributed to more than 25% of the 2021 designations:
27 individuals were sanctioned under the new anti-corruption sanctions, eight individuals
under the human rights sanctions.
With 50 designations, Belarus was the largest contributor to the new targets.
A spike in removals can be observed in September, corresponding to Iraqi targets.

Looking Forward
All signs point toward the continued use of sanctions in relation to various foreign policy issues.
However, recent developments also suggest a renewed focus on maximizing sanctions effectiveness.
First, we expect to see more coordination among western powers and their allies to maximize
the effects of sanctions for issues where no consensus can be reached at the United Nations Security
Council. At the time of publishing, we are seeing increased sanctions activity resulting fromthe situation in Eastern Europe, and these types of pluritalateral sanctions were also evidenced
in 2021, through the coordinated sanctions of the U.S., EU, UK and Canada on Belarus.
Second, sanctions seem to have reached somewhat of a tipping point. With the increasing useof sanctions (particularly unilateral measures), foreign states tend to develop counter-sanctions
mechanisms which in turn cause conflicts of laws and legal uncertainties, particularly for global
companies. Comprehensively sanctioned countries and entities continue to develop sophisticatedevasion tactics, and more sanctions do not cause additional pain to the targets, but rather
additional incentives to circumvent them (for instance by limiting a country’s relianceon the U.S. dollar or the SWIFT network).
Lastly, the unintended impacts of sanctions (particularly in relation to humanitarian aid and access to
medical equipment) are becoming increasingly problematic. Sanctions against foreign governments
or groups have had devastating impacts on ordinary citizens, as exemplified in the 2021 humanitariancrisis in Afghanistan or through the persistent difficulties for sanctioned countries to gain access topersonal protective equipment, ventilators and vaccines throughout the pandemic.

For 2022 and beyond, we expect sanctioning countries to increase their focus onsanctions effectiveness. This will be achieved by tailoring measures that maximize thepain for the target while limiting impacts for civilian populations. More effective sanctions
will also require increased cooperation among states to form a common front against thematerial threats to international security and fundamental human rights.”–Vincent Gaudel
Compliance Expert, LexisNexis® Risk Solutions

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