Table 16
Recommendations for Scenario 2

Urgent priorities Longer-term priorities
Congress
  • Initiate public reviews of the Russia policy and effectiveness of sanctions
  • Launch formal investigations into enforcement gaps
  • Require quarterly reporting from OFAC and BIS on license issuance, enforcement actions, and industry lobbying activity
  • Fund the expansion of enforcement teams at Treasury and Commerce departments
  • Conduct public hearings to develop a reinvigorated longer-term sanctions policy
US governmentProduce assessments of achieving maximum efficiency of sanctions policies with resources that are still available
  • Produce assessments of the impact of stalled sanctions policy and recommendations to reinvigorate it
  • Produce assessments of Russia’s reaction to lost sanctions momentum and its efforts to seize the emerged window of opportunity, develop new set of recommendations on reacting to new circumstances
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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