Russia sanctions and export controls : U.S. agencies should establish targets to better assess effectiveness

Title page 1

Contents 3

Highlights 2

Letter 7

Background 10

U.S. Sanctions and Export Controls on Russia 10

U.S. Sanctions and Export Controls Authorities 13

Roles of Relevant Federal Agencies in Sanctions and Export Controls 15

U.S. Agencies Have Not Established Objectives Linked to Measurable Outcomes with Targets for U.S. Sanctions and Export Controls on Russia 19

Objectives of U.S. Sanctions and Export Controls on Russia Fell into Three Broad Categories 20

U.S. Agencies Have Not Established Specific Objectives that are Linked to Measurable Outcomes with Targets 24

U.S. Agencies Have Made Some Progress Toward Broad Sanctions and Export Controls Objectives, but Challenges Remain 27

Russian Economic Indicators Declined in 2022 Following Sanctions and the Invasion, then Partially Recovered 27

Russian Actions and Other Factors Diminished Effectiveness of Oil Price Cap and Other Sanctions 33

U.S. Export Controls Have Hindered Russia's Efforts to Access Military Technology, but Enforcement Challenges Remain 38

Agencies Have Taken Actions to Hold Russian Malign Actors Accountable, but Have Challenges in Assessing Their Effectiveness 46

U.S. Agencies Obligated Over $164 Million in Supplemental Funding for Activities Related to Russia Sanctions and Export Controls 52

Agencies Obligated Over $164 Million in Ukraine Supplemental Funding 52

Agencies Used Ukraine Supplemental Funding to Implement and Enforce Russia Sanctions and Export Controls 53

Some State Offices Did Not Assess Risks to Sanctions Activities in the Absence of Additional Funding 55

Some State Offices Did Not Assess Risks to Sanctions and Export Controls Activities in the Absence of Future Funding 55

Justice's Plans for the Use of Its Unobligated Ukraine Supplemental Funding 57

Conclusions 58

Recommendations for Executive Action 59

Agency Comments and Our Evaluation 59

Appendix I: Objectives, Scope, and Methodology 66

Appendix II: List of Knowledgeable Stakeholders 73

Appendix III: Technical Details on Synthetic Control Methodology 74

Appendix IV: Additional Details on Literature Review 89

Appendix V: Timeline of Selected Events Related to the Price Caps on Russian Crude Oil and Petroleum Products 95

Appendix VI: U.S. Agencies' Uses of Ukraine Supplemental Funding for Russia Sanctions and Export Controls Activities 97

Appendix VII: Comments from the Department of State 103

Appendix VIII: GAO Contact and Staff Acknowledgments 107

Tables 4

Table 1. Examples of U.S. Sanctions and Export Controls on Russia, February 2022-October 2024 12

Table 2. U.S. Agencies' Obligations for Russia Sanctions and Export Controls from Ukraine Supplemental Appropriations Acts, as of September 30, 2024 52

Table 3. Agencies' Reported Uses of Ukraine Supplemental Funding for Russia Sanctions and Export Controls-related Activities 54

Table 4. List of 11 Knowledgeable Stakeholders 73

Table 5. Variables Used in Synthetic Control Estimate of Real Gross Domestic Product (GDP) Percentage Change, Averaged over 2017-2021 79

Table 6. Comparison Country Weights Used to Calculate Counterfactual for Russia When Estimating Effect on Real Gross Domestic Product (GDP) Percentage Change 80

Table 7. Synthetic Control Treatment Effects for Real Gross Domestic Product (GDP) Percentage Change, Results of Permutation Tests, and Sensitivity Analysis 82

Table 8. Variables Used in Synthetic Control Estimate of Real Gross Domestic Product (GDP) Per Capita, Averaged over 2017-2021 85

Table 9. Comparison Country Weights Used to Calculate Counterfactual for Russia When Estimating Effect on Real Gross Domestic Product (GDP) Per Capita 86

Table 10. Synthetic Control Treatment Effects for Real Gross Domestic Product (GDP) Per Capita, Results of Permutation Tests, and Sensitivity Analysis 87

Figures 4

Figure 1. Examples of Objectives of U.S. Sanctions and Export Controls on Russia from Agency Press Releases, February 24, 2022-February 23, 2024 23

Figure 2. Comparison of Russia's Economic Growth to Counterfactual Calculated for Russia, 2017-2029 30

Figure 3. Russia's Estimated Oil (Crude and Product) Export Revenue and Volume 36

Figure 4. Dollar Value of World Exports to Russia of Common High Priority List (CHPL) Products, 2019-2023 41

Figure 5. Task Force KleptoCapture Coordinated the Seizure of the Yacht, Amadea, Owned by a Russian Oligarch, Announced on May 5, 2022 47

Figure 6. Comparison of Russia's Economic Growth to Counterfactual Calculated for Russia, 2017-2029 78

Figure 7. Comparison of Russia's Real Gross Domestic Product (GDP) Per Capita to Counterfactual Calculated for Russia, 2017-2029 84

Figure 8. Timeline of Selected Events Related to Price Caps on Russian Crude Oil and Petroleum Products, September 2022-July 2025 95