1 Berman, Howard, Dobriansky, Paula J., Eckert, Sue E., Ann Elliot, Kimberly, Goldwyn, David L., Harrell, Peter, Kassinger, Theodore, et al. , Maintaining America's Coercive Economic Strength: Five Trends to Watch in American Sanctions (Washington, D.C.: Center for a New American Security, 2019), p. 4, www.cnas.org/publications/reports/maintaining-americas-coercive-economic-strength.
2 Gordon, Joy, “The Hidden Power of the New Economic Sanctions,” Current History 118, no. 804 (January 2019), p. 3.
3 Amnesty International, The US Embargo against Cuba: Its Impact on Economic and Social Rights (London: Amnesty International Publications, 2009).
4 See, for example, Fassbender, Bardo, Targeted Sanctions and Due Process: The Responsibility of the UN Security Council to Ensure that Fair and Clear Procedures Are Made Available to Individuals and Entities Targeted with Sanctions under Chapter VII of the UN Charter (Berlin: Humboldt University Berlin, 2006).
6 “Treasury Sanctions 13 Current and Former Senior Officials of the Government of Venezuela,” U.S. Department of the Treasury, July 26, 2017, www.treasury.gov/press-center/press-releases/Pages/sm0132.aspx; and “The Outlook for 2018: U.S. Economic and Trade Sanctions against Venezuela” (online panel proceedings, Gibson, Dunn & Crutcher LLP, March 13, 2018), p. 10, www.gibsondunn.com/wp-content/uploads/2018/03/WebcastSlides-US-Economic-and-Trade-Sanctions-Against-Venezuela-2018-03-13.pdf.
9 Eckert, Sue E., “The Evolution and Effectiveness of UN Targeted Sanctions,” in van den Herik, Larissa, ed., Research Handbook on UN Sanctions and International Law (Cheltenham, U.K.: Edward Elgar, 2017), p. 66.
10 Office of Foreign Assets Control, List of Foreign Sanctions Evaders Sanctioned Pursuant to Executive Order 13608 (Washington, D.C.: U.S. Department of the Treasury, February 7, 2019).
12 Department of the Treasury, Office of Foreign Assets Control, “Appendix A to Part 501—Economic Sanctions Enforcement Guidelines,” 31 CFR, Federal Register 74, no. 215 (November 9, 2009), www.federalregister.gov/documents/2019/05/21/2019-10616/addition-of-entities-to-the-entity-list. Under § 744.11(b) (Criteria for revising the Entity List) of the EAR, persons for whom there is reasonable cause to believe, based on specific and articulable facts, that he/she has been involved, is involved, or poses a significant risk of being or becoming involved in activities that are contrary to the national security or foreign policy interests of the United States and those acting on behalf of such persons may be added to the Entity List.
14 Deripaska v. Mnuchin, Complaint for Declaratory and Injunctive Relief, U.S. District Court, District of Columbia, March 15, 2019, p. 15.
18 Dackiw et al., “Impact of Recent US and EU Sanctions on the Middle East.”
21 Marc J. Bossuyt, “The Adverse Consequences of Economic Sanctions on the Enjoyment of Human Rights” (working paper E/CN.4/Sub.2/2000/33, United Nations Commission on Human Rights, June 21, 2000), p. 10.