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A senior member of President Joe Biden’s administration said Tuesday that federal officials are reviewing U.S. sanctions programs to ensure they are fairly and effectively implemented.

The review may take months, but to ensure the flow of humanitarian aid to vulnerable individuals in blacklisted jurisdictions, the Treasury and State departments, which administer the bulk of U.S. sanctions, may make the most urgent revisions before the process concludes, said Peter Harrell, a senior director on the National Economic Council and National Security Council.

U.S. sanctions programs give the federal government the ability to freeze billions of dollars in assets and cause severe economic disruptions, Harrell said during a panel of the online ACAMS Sanctions Space Summit.

“But … sanctions can be most impactful in actually achieving policy goals when they are targeted, singling out specific bad actors and their enabling networks,” Harrell said. “The goal of sanctions should not be to punish ordinary citizens for the actions of their leaders.”

Harrell delivered his remarks just as the Treasury Department’s Office of Foreign Assets Control blacklisted seven Russian officials implicated in the poisoning and imprisonment of opposition leader Alexei Navalny. OFAC also blacklisted two senior leaders of Ansarallah, an Iran-backed Yemeni militia more commonly known as the Houthis.

Tuesday’s designations against the militia leaders follow Secretary of State Antony Blinken’s decision to withdraw Ansarallah’s blacklisting as a foreign terrorist organization on Feb. 12, less than a month after the State Department imposed the measure during former President Donald Trump’s waning days in office.

Harrell pointed to OFAC’s designations of the group’s leaders, rather than the entire group itself, as an example of the more targeted approach to sanctions that the Biden administration intends to pursue while grasping and mitigating the “unintended consequences” of broader, sweeping economic restrictions.

“[The administration is] firmly committed to … putting pressure on the Houthis and on their backers … to stabilize Yemen,” Harrell said. “The designation of Ansarallah threatened to impair the provision of needed humanitarian assistance to Yemen, which would risk ultimately expanding both the humanitarian catastrophe … and contributing further to regional instability.”

Under Biden, OFAC has also targeted more than a dozen military officials and their associates in Myanmar for their role in the Feb. 1 coup against the nation’s elected government. Treasury Secretary Janet Yellen said Feb. 11 that more blacklistings may follow if the Burmese military’s crackdown on demonstrators continues.

“The administration called on the military to immediately restore power to the democratically elected government … release unjustly detained individuals and ensure peaceful protests are not met with violence,” Harrell said Tuesday. “Sanctions need not be permanent and the administration is prepared … to lift sanctions if behavior really does change.”

The Biden administration has pledged to work with allies in selecting targets for designations, use them only as part of a broader diplomatic strategy, and account for the possibility that overreliance on sanctions could discourage the use of the U.S. dollar and financial system, Harrell said.

Harrell also committed Tuesday to engage in an ongoing dialogue with financial institutions and other businesses to glean insights on how sanctions programs work in practice, and identify those that do not.

“It can be very valuable to drill down on exactly what regulatory provision or action is actually the source of the legal problem,” Harrell said. “I also think it can be very helpful to draw comparisons across sanctions regimes, where you see something working better in Venezuela because the licenses for dealing with the government … are slightly different than the licenses for dealing with the governments of Syria [or] Iran.”

Contact Valentina Pasquali at vpasquali@acams.org