Honing the Economic Weapon: Application of the Prosecutor's "Toolkit" in Sanctions Enforcement
Adams proposes a relatively modest reform of the current US sanctions regime. In short, sanctions regulators and designating authorities should take seriously the assertion that sanctions are intended to effect a change of behavior—they should approach dealings with sanctioned individuals and entities in the manner that US federal prosecutors construct large-scale organized crime cases. That approach requires a devotion of significant resources to communication with targets of prosecutions, and even indicted defendants, in order to obtain cooperation in pursuing and dismantling larger and more nefarious criminal enterprises. This mentality, in turn, requires certain prerequisites: an intra-agency cultural goal of building “bigger” cases, a decision-making process insulated from partisan politics, and flexibility to offer rewards in exchange for significant and substantive assistance to the United States.
Recommended Citation: Andrew Adams, Honing the Economic Weapon: Application of the Prosecutor's "Toolkit" in Sanctions Enforcement, 48 Fordham Int'l L.J. 1001 (2025).