Dr. Keith Preble

I didn't find any errors or problems in the data set this year. The new version will be published on 12/31 barring any new enforcement actions between now and the end of 2025. I will also publish an updated codebook with the figures presented here, as well.

Happy Holidays! 🎄

In 2026, I want to systematize the sanctions violations to make it easier to create figures and tables in R, Stata, and Python. I also want to clean up the sector coding, as well. /11

The other factor to note in 2025 was the three individuals targeted. While targeting of individuals is not unusual, there hasn't been this many individuals targeted in a single year for quite a while: 3 in 2025, 2 in 2024, 1 in 2023, 0 in 2022, and 1 in 2021, and so on. /10

The GVA Capital, Ltd. case is an excellent of example of why cooperation matters (even if you don't voluntarily disclose and have a potentially egregious violation). The OFAC EA online notes how the entity "willfully violated U.S. sanctions" and how the entity acted against legal advice received. /9

The Trump Administration has one mega-enforcement action that accounted for over 82% of OFAC's 2025 penalties, its enforcement action against GVA Capital, Ltd. published on 12 June 2025. GVA Capital Inc. continued to manage assets and investments for a blocked person and ignored an OFAC subpoena. /8

Enforcing US Economic Sanctions: Why Whale Hunting Works Published in The Washington Quarterly (Vol. 43, No. 1, 2020)

A shorter more policy-oriented piece we wrote is also available in The Washington Quarterly, also from 2020: www.tandfonline.com/doi/abs/10.1...

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Going Fishing versus Hunting Whales: Explaining Changes in How the US Enforces Economic Sanctions How economic sanctions are enforced undoubtedly affects their chances of success. Yet, to date, a lot remains unknown about how governments actually enforce their sanctions. To shed light on the wa...

For a discussion in how OFAC's sanctions enforcement practices changed, see this article Bryan R. Early and I wrote in 2020 published in Security Studies: www.tandfonline.com/doi/full/10....

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Trump II shows a marked decline in the enforcement penalty amounts compared to Trump I and Biden. Of course, nothing can top the Obama administration's "whale-hunting" strategy that reflect OFAC's newly acquired penalty powers thanks to IEEPEA. /5

Most of the enforcement actions published on OFAC's web site (ofac.treasury.gov/civil-penalt...) were non-egregious. In one case, only 8 of the 21 EA's were egregious. /4

The number of non-voluntarily disclosed enforcement actions was higher, which may have been due to the three individuals targeted with sanctions enforcement in 2025, the most seen several years. /3

The first year of the Trump Administration was an interesting mix of enforcement actions with a strong focus on Russia for obvious reasons followed by Iran, Venezuela, and Cuba. I'm curious to see what 2026 brings! /2

🎄 It's that special time of year again when the OFAC Enforcement Data Set gets updated! ☃️

I will publish the updated version of the dataset to Harvard Dataverse on 31 December. Last year, OFAC snuck in an EA on the last day of the year, so I'll wait until then to update the data set. /1

Australia’s world-first social media ban begins as millions of children and teens lose access to accounts Accounts held by users under 16 must be removed on apps that include TikTok, Facebook, Instagram, X, YouTube, Snapchat, Reddit, Kick, Twitch and Threads under ban

If parents are just going to make accounts for their children and/or educate them on how to use a how can the policy be evaluated?

www.theguardian.com/australia-ne...

When the Democratic Recession Comes Home Michael McFaul wants more democracy promotion. Is now the time?

In his new book, Michael McFaul offers a straightforward prescription for wavering democrats contending with this fraught moment in American politics: double down.

US military developing small refineries for critical minerals The U.S. military said it plans to develop a fleet of small-scale refineries to produce critical minerals used to make bullets, armor and other types of weaponry, a move aimed at developing domestic sources for niche materials that Chinese miners have long controlled.

US military developing small refineries for critical minerals reut.rs/44LQUOy

🎂 Happy birthday to the European flag! 🇪🇺

🗓️ In 1985, it became the EU’s emblem, but did you know it was first adopted 70 years ago today by the Council of Europe?

Learn more about the EU flag facts and figures ➡️ link.europa.eu/cxYjT4

Survey: Finns' willingness to defend country remains high Four out of five respondents said that in the event of a military attack, they would be willing to participate in national defence operations, based on their abilities and skills.

In Finland, willingness to defend the country remains high at 78 percent and NATO also enjoys 84 percent approval rating

🎉 Happy 70th Birthday to the European Flag!

🇪🇺 #OnThisDay the flag was adopted by the @coe.int Committee of Ministers. It became the flag of the EU in 1985.

Symbolising the EU and Europe more broadly, it stands for the values and shared identity of millions of Europeans united in their diversity!

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Republicans push high deductible plans and health savings accounts A Republican call to give Americans cash instead of health insurance subsidies revives an old idea that has left millions with medical debt.

Health care in the US is an abysmal mess: www.npr.org/sections/sho...

For all the discussion of Xi being pro-state, the gap between private and public wealth has continued to grow under his watch

When I heard of the indictments against Letitia James and Lisa Cook, my first thought was I hope someone does a piece on the president’s mortgages. ProPublica’s journalists deliver.

Thailand-Cambodia live: Thailand launches airstrikes as border clashes reignite Simmering tensions erupted into new violence.

Southeast Asian countries have rarely engaged in military clashes among themselves in recent decades, with the use of cross-border air strikes even rarer. Follow our live coverage as the Thailand-Cambodia border tension unfolds reut.rs/4a2ne3l

Patent Law: An Open-Access Casebook, by Sarah Fackrell, Sarah R. Wasserman Rajec & Andres Sawicki, now with a turquoise cover!

Friends, I am so delighted to share that Version 2 of our FREE patent casebook is now available on SSRN: papers.ssrn.com/sol3/papers....

Great thread here!

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Verteidigungsministerium lässt X-Kanal ruhen Das Gebaren von US-Milliardär Musk rund um seine Social-Media-Plattform X lässt die Kritik daran immer lauter werden. Nun will das Wehrressort als erstes Bundesministerium X nicht mehr nutzen. Ganz we...

Dear European official accounts, just a reminder that it is possible to leave X behind - the German defence ministry did so in January 2025 and has not posted since.

Donald Trump awarded inaugural FIFA Peace Prize

I thought this was an SNL joke or something going around about the FIFA Peace Prize (this is what happens when you unplug for a couple of days):

www.nytimes.com/athletic/685...

If I had a garage and facilities to safely do it, I'd probably change the oil in my car and rotate my tires.

I think I've pivoted to that time of life where waking up between 4am-5am is routinized. Things I've accomplished in the last hour and a half: started my laundry, cleaned out my humidifier, changed the cat's water fountain, fed the cat, swept my kitchen, & bought some Xmas jazz music on iTunes.