| Congress | - Launch investigations into enforcement gaps and require quarterly reporting from OFAC and BIS on license issuance, enforcement actions, and industry lobbying activity
- Review the impact of DOGE actions on sanctions enforcement capacity
| - Codify sanctions to the largest extent possible to prevent unjustified dismantling in the future
- Assist the government to enhance OFAC and BIS staffing and available resources
- Launch formal investigations into enforcement gaps and require quarterly reporting from OFAC and BIS on license issuance, enforcement actions, and industry lobbying activity
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| US government | - Return to the practice of regularly updating Russia sanctions lists, including with secondary sanctions against third-country parties
- Enhance OFAC and BIS staffing and available resources
- Enforce stricter export controls
- Work with the private sector to step up KYC and end-customer controls regarding military and sensitive technology
- BIS should shift to impact-based targeting, prioritizing entities central to Russia’s military-industrial base and exercising rigorous export controls
- Cut off all Russian banks from SWIFT
- Sanction Russian fertilizers, chemical products, full list of nonferrous metals
| - Increase coordination with other Western democracies, consider recreating COCOM 2.0
- Spearhead a reinvigorated transatlantic alignment strategy, particularly in coordinating enforcement timelines with the EU and Japan to prevent circumvention windows
- Apply diplomatic pressure on countries (e.g., UAE, Central Asia, South Caucasus) identified in US export diversion data
- Integrate secondary sanctions warnings into all bilateral trade dialogues
- Consider lowering the oil price cap for Russia within the G7 framework
- Assist the EU with implementation of the program of gradual phasing out of Russian natural gas and LNG
- Build a specialized unit for Russia sanctions enforcement, including forensic analysis of financial flows and shadow fleet shipping activity, within OFAC
- Adjust exports licensing process in high-risk export categories that should be subject to stricter export controls
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| NGOs, civil society groups | - Step up investigative efforts to uncover sanction evasion schemes
- Focus on watchdog work that monitors carveouts, lobby for tighter enforcement, and disseminate evidence of violations to Congress and investigative media
| - Increase public awareness of the actual achievements of sanctions policy in terms of enhancing the security of the US and the Western world
- Increase public awareness of the risks posed by dismantling or the gradual erosion of sanctions
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