Between claims of "financial carpet bombing" and dire
warnings regarding the "weaponization" of the U.S.
dollar, it was difficult to avoid hyperbole when describing the use
of economic sanctions in 2019. Sanctions promulgated by the U.S.
Department of the Treasury's Office of Foreign Assets Control
("OFAC") have become an increasingly prominent part of
U.S. foreign policy under the Trump administration. For the third
year in a row, OFAC blacklisted more entities than it had under any
previous administration, adding an average of 1,000 names to the
Specially Designated Nationals and Blocked Persons
("SDN") List each year—more than twice the annual
average increase seen under either President Barack Obama or
President George W. Bush. Targets included major state-owned oil
companies such as Petróleos de Venezuela, S.A.
("PdVSA"), ostensible U.S. allies such as Turkey
(and—almost—Iraq), major shipping lines, foreign
officials implicated in allegations of corruption and
