Dubious Delistings and the Misuse of Targeted Sanctions

by Amanda Strayer and Malak Harb

During the Trump administration’s first 14 months, Human Rights First has identified a growing pattern of questionable actions where individuals or companies who had been targeted with U.S. sanctions for alleged human rights abuse and corruption were granted sanctions relief.

In our newly published U.S. Sanctions Delisting Tracker, we have documented over 170 individuals and companies that the current administration has removed from U.S. sanctions lists or granted licenses, often with little to no explanation or justification provided.

Given our focus on human rights abuse and corruption, the tracker omits delistings of sanctions targets under the counterterrorism and counternarcotics programs. For readability, it also omits several hundred targets who were delisted in the broad U.S. withdrawal of Syria-related sanctions last year; those delistings came in response to the fall of the Assad regime and were accompanied by a broad and bipartisan congressional mandate for sanctions relief.

Sanctions delistings can be an appropriate measure for those who have changed their behavior or otherwise been held accountable for abuses; however, the overall circumstances of these delistings suggest the relief may in some cases have been a favor for political allies. This is especially concerning as the rate of these delistings appears to have far outpaced comparable actions by the previous administration.

Last year, we convened a panel of human rights experts and advocates to discuss specific recent controversial delistings that illustrate this trend and the ways in which the lack of consistency and transparency have undermined the goals of accountability.

Sanctions as Tools of Accountability or Politics?

One of the early and most stark signals of the Trump administration’s intent to use sanctions relief to favor political allies came with the delisting of Hungarian minister Antal Rogán. Panelist Tjaša Feher (EU Advocacy Manager, European Center for Research, Transparency and Accountability) discussed how Rogán – considered an architect of Hungary’s system of corruption under Viktor Orbán – had been sanctioned under the Global Magnitsky program in President Biden’s final month in office. The move was seen as complementing existing European Union (EU) budgetary measures against Hungary for undermining the rule of law, though the timing left little opportunity for the Biden administration to try to leverage its sanctions for greater impact.

Three months later, the new Trump administration lifted the sanctions on Rogán, which Orbán’s government took as a victory and credited to its close ideological ties with the new administration. Offering a vague explanation that the sanctions were “inconsistent with U.S. foreign policy interests,” the State Department did not appear to have secured any meaningful accountability for Rogán’s alleged corruption as a condition for delisting. The move sent a clear signal to civil society that political ties may override the administration’s use of sanctions as tools of accountability.

Another early example of the Trump administration’s withdrawal of accountability-driven sanctions came with the termination of the West Bank sanctions program (E.O. 14115) on President Trump’s first day in office. The program had been a limited, late response by the Biden administration to hold violent Israeli settlers in the West Bank accountable, and failed to extend to abuses committed in Gaza. However, as panelist Michael Omer-Man (Director of Research for Israel-Palestine, DAWN) explained, the sanctions had underscored that impunity for Israeli violence was not absolute; rescinding the sanctions, on the other hand, underscored that the Trump administration’s priorities did not include accountability.

Justyna Gudzowska (Executive Director, The Sentry) explained that sanctions delistings can become especially problematic when they do not appear to follow proper process and interagency review, and instead seem to be driven by lobbying and political considerations. Concerningly, the Trump administration’s approach in several instances has appeared to diverge from the delisting practices of prior administrations. 

Corporate Impunity and a Lack of Transparency

The pattern of questionable delistings has extended beyond financial sanctions to include Withhold Release Orders (WROs, or import bans) imposed by U.S. Customs and Border Protection (CBP). As Charity Ryerson (Executive Director and Founder, Corporate Accountability Lab) explained, the U.S. Tariff Act prohibits the importation of goods that have been produced with forced labor to the United States, making it an effective tool to protect the U.S. market while combatting forced labor. Beginning in November 2022, a major Dominican sugar producer, Central Romana Corporation, had been subject to a WRO due to evidence of decades of forced labor of mainly Haitian workers in the Dominican Republic.

After the WRO was imposed and effectively blocked the U.S. importation of goods produced by Central Romana, the company invested significant resources in lobbying efforts to have the WRO lifted. With little transparency into the process, the Trump administration in April 2025 quietly lifted the WRO with little explanation, and despite evidence that the company had failed to take the remediation steps generally recommended by CBP. This sent the message to corporations that it may be more effective to engage in lobbying than remediating forced labor.

The Trump administration, last summer, also delisted three individuals and their arms businesses that were linked to the abusive Myanmar military junta. Gudzowska underscored that there were no explanations or press releases issued about these delistings, a practice that differed from major actions taken by previous administrations.

The Impact of Misuse on Sanctions’ Effectiveness

When sanctions that are meant to bring accountability for human rights abuses and corruption are unduly influenced by other factors, their effectiveness is greatly diminished. Feher explained that such sanctions would only be truly effective when they are targeted, consistent, and paired with other regional and international tools to maximize their impact. Openly discussing the misuse of sanctions is an important way of pushing back against it.

Omer-Man emphasized that, in order for sanctions to function as tools of accountability, the governments imposing them must also be committed to a baseline level of transparency. Without that transparency, the tool can be dangerous.

Challenging the Misuse of Sanctions Tools

The panel discussion identified several strategies that stakeholders could pursue to push back against the misuse of these important accountability tools.

For the lifting of sanctions and other measures, Congress could play a greater role in legislating enhanced transparency and creating more procedural safeguards against abuse. The Office of Foreign Assets Control (OFAC) could enhance their scrutiny of delisting petitions and resist requests that do not meet certain accountability criteria, such as those outlined in the Global Magnitsky Act. Additionally, banks and the private sector should independently assess the risks certain actors pose, understanding that a delisting may not signify that the actor is no longer engaged in abusive or corrupt conduct.

Civil society groups have also taken steps to navigate the changing sanctions landscape in the United States. Some organizations have chosen to be more selective in the information they share with U.S. government agencies, given doubts about the prospects of action and of confidentiality, and to default to publicizing their sanctions advocacy, rather than acting behind the scenes, in cases that the current administration may be less likely to act on. Many groups have also focused their advocacy on jurisdictions other than the United States – including the UK, Canada, EU, or Australia – that have similar targeted sanctions focused on human rights and anticorruption.

By monitoring dubious delistings, highlighting misuses, and advocating for reforms, civil society can push back against actions that are eroding the effectiveness and legitimacy of sanctions – and reaffirm the appropriate role that these tools should play to advance accountability for human rights abuses and corruption.