Sanctions use has escalated — permanently
Designations per calendar year. The 2022 step change is Russia’s invasion of Ukraine, and output has stayed at that level since.
2001–2016. Averaged 462 designations a year. Sanctions were one tool among many, dominated by narcotics and terrorism cases.
2017–2021. Volume roughly doubles. The Iran “maximum pressure” campaign produces the single largest day on record — 703 entities on 5 November 2018.
2022–present. A step change, not a spike: above 2,500 a year, every year.
Each administration escalated on the last
Annualised, so four-year and eight-year terms compare fairly. Trump II covers Jan 2025 – Jul 2026.
The Biden administration issued designations at 6.7× the Bush rate. The trend predates the Ukraine war: every administration since 2001 has out-designated its predecessor on a per-year basis.
Trump II is running below Biden’s wartime peak, but well above every pre-2021 administration.
From a Colombian drug program to a Russia program
Share of each era’s designations accounted for by its single most-targeted country — a measure of concentration as much as geography.
Under Bush, nearly four in ten designations were Colombian — the cartel networks and their front companies.
Under Biden, half of all designations were Russian. No previous administration concentrated the tool so heavily on one country.
Trump II is the most geographically diversified era on record: no single country exceeds 11%.
Five countries, five different stories
Designations per year for the five most-designated jurisdictions.
Russia. Near zero until 2014 (Crimea); the 2022 invasion produces the largest sustained campaign in the dataset. Iran. Persistent throughout, spiking in 2018 with the JCPOA withdrawal and again in 2025–26 around oil and shipping.
Colombia. Dominant early, then falls away as the cartel program winds down. Mexico. The one constant — cartel designations in every era. China. Emerges late, rising steadily from 2018.
The tool now reaches almost everywhere
Distinct countries and jurisdictions touched by designations each year.
In 2001 designations touched 20 countries. In 2024 they touched 113.
Part of that is simply more sanctions. But it also reflects a change in what is being sanctioned: modern designations map networks, and networks are transnational. A single Russian procurement case now routinely pulls in intermediaries in the UAE, Hong Kong, Turkey and China.
From crime to geopolitics
Share of each era’s designations by thematic program grouping.
Counternarcotics was half of everything OFAC did under Bush. By the Biden administration it was 4%.
Russia and Ukraine programs went from literally zero before 2014 to two-thirds of all designations under Biden. Iran is the through-line — material in every era, and the largest single category under both Trump administrations.
What Treasury says the target actually did
Text-mined from the same-day Treasury press release for each designation — the stated reason, not an inference. A designation can mention more than one conduct, so these do not sum to 100%.
Drug trafficking collapsed from 39% of designations to under 5%.
Military and defence-industrial supply rose to 19% under Biden — sanctioning the war economy itself.
Oil and shadow-fleet smuggling is the signature of the current era at 22%, reflecting the shift to enforcement against evasion infrastructure.
From naming people to mapping companies and ships
Share of each era’s designations by type of target.
Under Bush, six in ten designations were individual people — the kingpin model. Today the majority are companies: designating a network’s corporate layer reaches more economic activity than naming its principals.
Vessels have quadrupled as a share, from 4% to 15%. Sanctioning specific hulls by IMO number is the defining technique of the oil-enforcement campaigns against Iran and Russia.
Getting off the list is rare — and getting rarer
Designations added versus removed, by the era in which each happened.
Obama is the outlier: 2,762 removals, including large housekeeping actions that cleared closed narcotics and Balkans cases.
Biden removed just 0.11 entries for every one added — the list became almost pure accumulation. Trump II has resumed active pruning under an explicit sanctions “modernization” initiative.
What the data suggests
24,027 designations added, 4,430 removed. The list is an accumulating stock, and the compliance burden accumulates with it.
Every era has had a dominant target. Capacity built for one campaign is slow to redeploy to the next.
The shift to companies, vessels and third-country intermediaries means the list is now a map of supply chains.
Front companies and shadow-fleet logistics are now among the most common stated reasons for designation.