Disclaimer 

Some of the data presented in this study was collected from unofficial sources, including online articles and our personal connections to informed individuals. Given the nature of the data, and despite our best efforts to cross-check the information provided by various sources, we cannot guarantee the accuracy of all details. If you wish to suggest a revision, please use this form.

Note that we excluded the US-sanctioned officials and employees of the Scientific Studies and Research Center (SSRC), 269 individuals who were all sanctioned at once in April 2017. When collecting the data for the study, we struggled to identify the vast majority of those individuals, highlighting their marginal role in the conflict.

Executive Summary

The subject of Western sanctions on Syria is a divisive one among analysts and policymakers interested in ending the misery of the country’s citizens. The division comes at a time when, more than ever, the country needs a comprehensive policy that ends the agony of most Syrians. This study assesses the effectiveness of the sanctions imposed on the regime of Bashar al-Assad by conducting a comprehensive review of their history, evaluating shortcomings in the current setup, and recommending ways to move forward.

Our conclusions and policy recommendations are based on analyzing data we collected on the individuals targeted by the United States (US) and the European Union (EU), as well as by studying existing literature on sanctions as a whole. This enabled us to compare US and EU approaches, assess the accuracy of stated information, and understand how sanctions are distributed across ethnic, religious, political, business, and security lines. 

​The first key finding of this study is that the EU has relied more heavily on sanctions than the US, especially early in the uprising. We also discovered inaccuracies in the information provided on targeted individuals, which raises questions about how the EU/US collect and revisit their information. We found incorrect familial relations and some logical conflicts. Moreover, there are apparent data-silo issues, reflecting a low level of coordination between the two. These findings highlight problems that impede the ultimate goal of sanctions: meaningful behavioral change that addresses injustice.

 We argue that sanctions have tended to target the tip of the iceberg rather than the vast local and international networks built over decades of illicit activities, thus limiting their effectiveness. This holds true despite the main breakthrough of secondary sanctions introduced in mid-2020 by the US Caesar Act, under which any person or entity, American or otherwise, who has significant dealings with any person or entity on Syria’s sanctions list — the so-called Specially Designated Nationals and Blocked Persons Lists (SDNs) — would be susceptible to sanctions. In addition, we believe that Assad’s choice not to concede because of sanctions is rational; from his perspective, the negative impacts of a political settlement would be greater than those imposed by sanctions.

​We recommend three main policy changes, which should (as much as possible) be taken as a single policy rather than three separate ones
 

  1. First, scrap all forms of country- and sector-based sanctions, especially on financial transactions; their harm outweighs their benefit, even for ordinary Syrians in the diaspora and opposition-held areas. This should be done in exchange for concessions, such as the release of prisoners. Instead, expand the use of travel bans and asset freezes.
  2. Second, implement a more active whole-of-Syria policy by making greater use of threats with “sticks” (punitive actions) and offering more “carrots” (incentives), as the current approach of relying on sanctions as the primary policy tool is unlikely to result in meaningful behavioral change. Incentivize Assad’s allies and expedite legal steps taken against regime officials and collaborators by leveraging the universal jurisdiction legislation in Western and international courts. 
  3. Third, improve the effectiveness of sanctions by taking a multifaceted approach: target the deep networks of the regime; make greater use of secondary sanctions; establish a rewards program to incentivize Syrian whistleblowers; and involve local organizations in collecting evidence and mapping the regime’s power structures to minimize errors and side effects in the current sanctions.
     

Background 

Given the limited use of force by the US and EU against the Syrian regime, the imposition of economic sanctions was the main nonviolent (or non-kinetic)1 pressure tactic employed to respond to the regime’s atrocities. The limited use of force is due to the Assad regime’s backing by global and regional powers like Russia and Iran — something Iraq, Libya, and ISIS lacked. This is despite the fact that prior to international coalition operations in September 2014, ISIS was responsible for only 0.5% of the total Syrian civilian casualties during the civil conflict; most of the rest were killed by the Assad regime.2

But are the sanctions worth it?

This study contributes to the ongoing debate over the effectiveness of the sanctions — which we define as meaningful behavioral change that addresses injustice — by conducting a comprehensive review, using existing literature and data we collected on individuals targeted by the US and the EU: 

  • In the first two sections, we provide a background history of both US and EU sanctions, highlighting their main differences and chronological variance. 
  • Next, we analyze all the published data on the US/EU sanctions targeting individuals involved with Syria, and share key findings and emerging themes. 
  • Then we highlight the key goals of sanctions as we see them, and two subsequent sections discuss the shortfalls as well as positive and negative impacts. In light of the stated goals and the effectiveness of the sanctions, we deduce the philosophy of the engaged parties, trying to justify their current behavior. 
  • Finally, the study concludes with policy recommendations.

​​

A Brief History of US Sanctions

Syria’s relationship with the West has never been calm for more than brief periods.3 Since 1979, the country has been designated a State Sponsor of Terrorism by the US government.4 The early 2000s witnessed US presidents issuing a series of Executive Orders (EOs) involving or targeting Syria in one way or another.

The first EO, no. 13224, was issued less than two weeks after the 9/11 attacks, which enforced US list-based sanctions against individuals and organizations facilitating terrorist activities.5 The names of those sanctioned were and are still published in SDNs, managed by the US Treasury Department’s Office of Foreign Asset Control (OFAC).6 The Mamoun Darkazanli Import-Export Company was listed under this EO; it belongs to the Syrian-German businessman of the same name. While independent from the Assad regime, Darkazanli was directly linked to al-Qaeda and personally knew three key members of the Hamburg Cell, which included several of the masterminds behind the 9/11 attacks.7 The EO entailed blocking the US-based assets and interests of listed individuals and organizations. 

In August 2003, EO 133158 targeted six Iraqi individuals with list-based sanctions; Syria is home to five of them who the US considered key participants in “terrorism, acts of public corruption, or their destabilizing activities in Iraq and Lebanon.” Two years later, several Syrian entities were sanctioned under this EO, including Gen. Zuhayr Shalish (known as Dhul Himma) and Asif Shalish, who used their Damascus-based SES International Corp. “as a vehicle to put military goods into the hands of Saddam Hussein and his regime."9

 A prohibition on the export of certain goods to Syria — mainly any goods containing more than 10% US-manufactured component parts, except for food and medicine — was first applied on May 12, 2004 under EO 13338.10 This was a turning point in Syrian-US relations, expanding the nature of sanctions from merely list-based to include sector-based ones. The significance of this EO is that it implemented the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003,11 which aimed to end the Syrian government’s support for terrorism, its presence in Lebanon, and its illegal import of Iraqi oil. High-profile Syrian generals were listed under EO 13338, including Rustom Ghazali, Ghazi Kanaan, and Assef Shawkat.

 2005 and 2006 witnessed another turning point, when the US began to target state-owned entities. On June 28, 2005, EO 13382 listed the SSRC for being part of a global network of weapons of mass destruction proliferators and supporters.12 In 2006, under Section 311 of the USA Patriot Act, sanctions were enforced against the Commercial Bank of Syria, the largest bank in the country, for its involvement in money laundering.13

 Few EOs were issued (like 13399 and 13441)14 from 2007 until the start of the Syrian uprising in March 2011. Beyond that point, additional EOs were issued and other entities were listed in line with the increasing level of human rights violations and sanctions evasion committed by Assad’s regime.

​A breakthrough in sanctions against the regime took place with the Caesar Syria Civilian Protection Act,15 which was passed by the US Congress in 2019 and took effect in mid-2020. The Act enabled the US government to impose a third type of sanctions beyond list-based and sectoral-based “primary” sanctions. The “secondary sanctions” permitted by the Act extend to non-US individuals as well as entities that are substantially involved with any primary-sanctioned entities and individuals related to Syria. In addition, as legislation passed by the US Congress, rather than simply an EO signed by a sitting president, the delisting process is made more difficult.16

Based on the data collected for this study, by the end of 2010 the number of individuals listed under US Syria-related sanctions was 11; by the end of April 2021 it had reached 178, excluding the 269 SSRC employees sanctioned en masse in April 2017.

A Brief History of EU Sanctions

In 1986, following the conviction of Nezar Hindawi for the attempted bombing of Israeli El Al Flight 016, and given his direct ties to the Syrian embassy in London, the European Commission applied minor sanctions against Syria,17 banning new arms sales.18 Twenty-five years later, in May 2011, EU sanctions against Syria grew rapidly within a few months, in response to the Assad regime’s brutal treatment of peaceful protestors. 

At the onset of the uprising, the EU and Syria had strong economic ties. The EU was involved in various projects and investments in Syria; the European Investment Bank (EIB)19 was investing in 17 projects, including the construction of power plants, and had a portfolio worth €1.3 billion (approx. $1.93 billion USD).20 In 2010, Germany, Italy, France, and the Netherlands collectively imported 80% of Syria’s crude oil, which accounted for 30% of Syrian government revenues that year ($4.1 billion USD).21

A September 2012 policy brief by Clara Portela of the Egmont Institute22 broke down the EU sanctions against Syria into five categories, based on their targets:

  • Targeting the Syrian government: Freezing the Syrian central bank’s assets in the EU and prohibiting EIB and EU entities from issuing new grants, trading public bonds, or giving loans to the Syrian government.
  • Targeting exposed individuals: Prohibiting individuals involved in the mass violations from entering the EU, as well as freezing their assets.
  • Targeting the repressive apparatus of the regime: Banning weapons and equipment that could further facilitate atrocities. This includes dual-use goods like chemicals used in both fertilizers and explosives. 
  • Targeting certain sectors: Drying up revenue sources that could exert powerful pressure on the regime and do serious harm. The EU mainly targeted the energy sector by prohibiting all imports of Syrian oil, as well as banning loans, insurance, and technology that could be leveraged within this sector. 
  • Targeting trade logistics: Restricting cargo-only flights and banning the export of luxury items like gold and diamonds. 

Based on the data collected, there were no EU sanctions on Syrian individuals prior to the March 2011 uprising; by the end of April 2021 the total had reached 280.

Figure 1: Timeline chart mapping the major events in Syria to US/EU sanctions distribution over time
Figure 1: Timeline chart mapping the major events in Syria to US/EU sanctions distribution over time.

What Can the Data Tell Us About the US/EU Sanctions So Far?

The EU and US sanctions data (individuals) from January 2011 to April 2021 is plotted in the cumulative area chart above. We overlaid the key events and turning points in the Syrian conflict to make it easier to understand the overall context of the sanctions and to speculate as to the reasoning behind them. Generally speaking, the succession of events and sanctions should not be interpreted causally as there may have been other factors driving both.

In terms of the relative appetite for using sanctions as a policy tool, the chart indicates that the EU has favored this tool more than the US. Part of the reason could be that it was assumed to be more effective for the EU, given the relative depth of its economic relations with Syria.

 Around 40% of EU sanctions were enforced in the first year of the uprising, compared with 25% of US sanctions enforced over the same period. This sharp increase is attributed to the swift change in the EU’s approach to enforcing political and economic reforms in Syria. Prior to 2011, the EU relied on the Euro-Mediterranean Partnership and the European Neighborhood Policy to influence such reforms,23 but it shifted gears to harsh economic sanctions when the peaceful uprising was met with brutality.

The two distributions have similar shapes from November 2012 to March 2020, but differ before and after this range. The EU’s sanction list grew rapidly in the first year of the uprising, from just 18 individuals in May 2011 to 108 by May 2012. This was not the case for the US; its list of entities grew more gradually until the very end of the chart, where we can see a sudden increase correlating with the activation of the Caesar Act.

The EU sanctions are generally aligned with outcomes of UN Security Council meetings, reflecting Western frustration with the repeated Russian and Chinese vetoes on condemning the atrocities committed by the Syrian regime. This is especially clear between the end of 2011 and the beginning of 2012. Both EU and US lists witnessed an upward surge in July 2012, which was followed by President Barack Obama’s famous “red line” speech that took place the following month.24 

Major chemical attacks in Khan al-Assal and Ghouta in March and August 2013 respectively did not lead to any noticeable change in the number of sanctioned individuals in the months that followed. However, the Khan Shaykhun chemical attack in April 2017 was followed by a slight increase in both lists. There could be several different reasons for that, including the lengthy investigation process of identifying the chain of command responsible for the earlier attacks and/or the fact that such severe attacks would most likely have been approved by already-sanctioned individuals. This highlights some of the shortcomings of the sanctions in stopping various atrocities, such as chemical attacks, which will be discussed later in the study.

Because the EU and US sanctions generally target individuals with significant seniority and influence in the regime, we studied how they align with ethnicity demographics in Syria, which could reflect the ethnic structure of power in the country. Note that the statistics presented below relating to ethnicity, sect/religion, and gender will consider Syrian nationals only (333 individuals). The full list of sanctioned individuals (366) will be considered for analysis beyond that.
 

Figure 2: Ethnicity shares of sanctioned Syrian nationals
Figure 2: Breakdown of sanctioned Syrian nationals by ethnicity.

 

Of the 333 sanctioned Syrian individuals, 97.4% are Arab, which is higher than their demographic share of the population, estimated at 80-85%.25 In contrast, Kurdish representation is notably marginal at 1.3%, even though the Kurds are the second-largest ethnic group in Syria at nearly 10%.26 But this is no surprise; power and authority in Syria have systematically disfavored the Kurds and applied a form of institutional racism against them. The remaining 1.3% includes other ethnicities like Armenians, Assyrians, Turkmen, and Circassians.

Moving to the religion (sect) distribution, 47% of sanctions are against Sunnis, who are estimated to comprise 74% of the Syrian population based on pre-war statistics.27 As for Alawites, the sect of President Bashar al-Assad, they account for 42.8% of those on the sanctions list, yet they represent only 12% of the population.28 It is important to note that there is uncertainty surrounding the sect-based population shares, as the Syrian census doesn’t include questions around this. But the sanctions share data confirms the widely accepted argument of how the Syrian regime advantaged Alawites in society at the expense of others.

The power structure and clientelism networks generally tended to maintain a balance between Sunni business elites, who have major influence on the economy, and Alawites, who influence the army and security apparatus. This is emphasized in the chart below, which shows a sect-based distribution of sanctioned individuals and their membership in the army and police apparatuses. Overall, we find that roughly a third of targeted individuals are affiliated with the army or security agencies (34.4%).
 

Figure 3: Affiliation of EU- and US-sanctioned Syrians with army or security agencies broken down by religion.  Note that total counts per religion/sect are shown in the middle of the bars.
Figure 3: Affiliation of EU- and US-sanctioned Syrians with army or security agencies broken down by religion.
Note that total counts per religion/sect are shown in the middle of the bars.

 

The Christian and Druze shares in the sanction lists are less than their representation in the population as a whole.29 The share of Christian sanctioned individuals is 6.6%, which is close to their share of the population. “Other” sects in the chart include Ismailis and Yazidis. The asymmetry in power distribution is not peculiar to race and religion; females are also significantly underrepresented, accounting for merely 6.6% of sanctioned individuals.

The characteristics analysis performed above was to inform the assessment of the sanctions programs and check how accurate the data is. Key findings are discussed in later sections, but we noticed that sanctions did not challenge — they probably reinforced — the status quo of power centers in the regime’s core network in terms of ethnicities, religion, and gender. Some would argue that this is not the direct purpose of sanctions, which is correct to some extent, but perhaps if sanctions are employed as part of a comprehensive policy this might change and lead to behavioral modification brought on by shifts in the power centers. This idea will be further highlighted in the policy recommendations section.
 

 Figure 4: Gender of Syrians targeted with EU and US sanctions
Figure 4: Gender of Syrians targeted with EU and US sanctions.

 

As part of the data enrichment process, we identified targeted individuals’ whereabouts. We found that 14.1% of them (51 individuals) live or spend substantial periods of time abroad. Of those 51 individuals, 18 are Syrian, shedding light on the sanctions’ reach beyond Syria’s borders. Some of these names include: 

  • Wael Abdulkarim and Ahmad Barqawi, who were listed along with their Syria and Dubai-based companies for their involvement in facilitating the shipment of aviation fuel to the Assad regime.30
  • Mudalal Khuri, who assisted sanctioned entities and managed business and financial interests in Russia for the Syrian regime.31 He was recently linked to the company that bought the ammonium nitrate that exploded at Beirut’s port in August 2020.32
  • The family members of Bashar al-Assad’s wife, Asma al-Assad (née Asma al-Akhras): Sahar Otri al-Akhras, Firas al-Akhras, and Eyad al-Akhras.33
     
 Figure 5: EU/US-Sanctioned individuals based on their place of living, within or outside Syria
Figure 5: EU/US-sanctioned individuals based on where they live, within or outside Syria.

 

Thirty-three of the 51 individuals living abroad are not Syrian; many are originally from Lebanon, Iran, and Turkey. There are also targeted individuals of other nationalities, such as Russia, the Netherlands, Cyprus, China, and Germany, most of whom are businessmen. The Caesar Act made secondary sanctions easier to impose, to exert greater pressure on the Syrian regime by tracing its third-party affiliates.

 Over the years, the Syrian regime has engineered sophisticated international networks to help it evade sanctions. In a recent interview with Firas Tlass, the son of Mustafa Tlass, Syria’s former minister of defense, he mentioned how smoothly the transition of wealth was completed from the Makhlouf family to Assad family members, within their European and Gulf Cooperation Council (GCC)-based accounts, after the recent spat between the families. 

This was achieved through a sophisticated network of business ownership schemes designed by Lebanese, English, and South African lawyers.34

​We do not have a comparable reference point against which to benchmark the 51 individuals living abroad, but given our perception of the spread of the regime’s network, we believe that cross-border and secondary sanctions are significantly underutilized. This is affirmed when we see that 46 of the 51 we identified were sanctioned by the US alone (during November 2014-November 2015 and December 2016-December 2017), four were sanctioned by the EU alone, and only one was sanctioned by both. Moreover, section 5.1 of this study discusses an additional point supporting this belief.

​From a legal point of view, secondary sanctions in the case of Syria are a very powerful tool in terms of their coverage and application. Section 7412(a)(2)(A)(iii) of the National Defense Authorization Act 2020 shows that secondary sanctions apply to “the foreign person [who] (A) knowingly provides significant financial, material, or technological support to, or knowingly engages in a significant transaction with ... (iii) a foreign person subject to sanctions pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) with respect to Syria or any other provision of law that imposes sanctions with respect to Syria.”35 In other words, apart from committing sanctionable behavior, a non-US person who has significant dealings with any sanctioned individual or entity on Syria’s SDN list can be sanctioned, too. 

We believe that if the secondary sanctions become more transparent and collaborative, their effectiveness can be greatly improved with the support of individuals and watchdog organizations in the Syrian diaspora. This point will be discussed further in the following sections.
 

Shortcomings of the Current Sanctions 

Now that we have provided a history of US/EU sanctions and highlighted key data findings, we will assess the shortcomings of the current sanctions imposed on the Syrian regime. We will analyze both US and EU sanctions in light of our data collection and desk review, and argue that the effectiveness of the current US/EU framework can be significantly enhanced by overcoming several issues.

 

The Targeted Individuals

When analyzing the sanctioned individuals, we found that most are already deeply rooted in the Assad regime. This fact hinders the primary goal of the sanctions: behavioral change. Instead, being targeted positively feeds these individuals’ ideological narrative in front of their supporters, strengthening rather than weakening their position within the regime. Furthermore, sanctions push them closer toward the regime and probably improve their chances of winning economic opportunities within Syria and accumulating capital, because they are no longer welcomed internationally.

Some individuals in Syria have even proclaimed their gratitude for being targeted by global sanctions — it proves how patriotic they are — and affirmed the “sacrifices” they have made to stand firm in the face of global conspiracies and imperialist attacks. One example is businessman Wasim Qattan,36 who responded to EU and US sanctions imposed on him by saying, “I had the honor of my name, Wasim Qattan, being included in the list of businessmen under European sanctions.”37

We believe sanctions should not stop at those deeply rooted in the regime, but should consider less entrenched individuals as well, like those with lower ranks in the formal chain of command, primarily because they are more likely to change behavior. Generally speaking, the proper depth of targeting still depends on the nature of the violation.

We also found that sanctions only target the tip of the iceberg when it comes to the regime's informal ties and general social capital. Less likely to be targeted are the vast networks of individuals that have been established over decades of illicit activities; if sanctions do target these networks, they focus only on small clusters and very few top players.

Networks like that of Assad’s regime, from a graph theory perspective, are resilient in structure, dynamic, and regenerative, highlighting the need for a constant revision of sanctions. Like any clandestine cell system, Syrian regime culprits can mitigate these penalties by devising novel ways to evade restrictions, like the use of cryptocurrencies, which are under consideration by the Central Bank of Syria,38 and the continuous help of hackers like the Syrian Electronic Army.39 The success of these evasion tactics implies that the current targeting styles not only make sanctions less efficient — more dangerously, they could make such networks antifragile, not only resisting and recovering from the stressor, but becoming stronger because of it.40

Damaging the strong ties of trust and loyalty between entities in a network leads to the activation of “weak ties,” a key mechanism to absorb the shock.41 In social network analysis, weak ties are the acquaintance relationships, used to enable collaboration and the diffusion of information. On a personal level, they can help you find a job.42 But on a clandestine network level, they enable network cells to maintain operational ties with the larger network from which supplies and benefits are drawn; the weak ties allow a cell to reattach to the network when its strong ties have been targeted or isolated by law enforcement or rival cells.43

Another problem that weakens the effectiveness of sanctions is the lack of an established rewards program and incentive mechanisms for whistleblowers who directly provide first-hand testimony. Such rewards can come in the form of financial compensation or physical protection, including offering asylum. Syria suffers from a severe lack of freedom of expression, and when brave citizens are offered no incentive to come forward — especially as some risk their lives when they reveal what is happening in-country or leak classified information — the sanction programs ignore a crucial potential contribution that could massively improve their effectiveness. 

Some key progress has been made in this area recently. The Bassam Barabandi Rewards for Justice Act44 bill was submitted to the US House of Representatives in February 2021. The act will help prosecute those who evade sanctions and violate human rights; if passed, it will be very useful in enhancing the effectiveness of US sanctions.

The current targeting style highlights that sanctions are often driven by behind-the-scenes arrangements. The published justifications for targeting an individual are in many cases not sufficient to convince the public; certain individuals who found their way onto the lists, like Karam al-Assad, were so insignificant that it was difficult to assess what type of behavior had earned them a spot. This has contributed to the growing perception that sanctions are driven solely by political moods and interests. Avoiding or delaying the listing of a person directly linked to violations in Syria could be seen as a political maneuver with the aim of winning over this individual as a potential facilitator in upcoming political settlements. An example of this is Samer Foz. According to Jihad Yaziji,45 sanctions on Foz were initially put on hold as some parties believed that he was nominated to play a role in a political settlement. This changed later; he was sanctioned by the EU in January 2019,46 and by the US in June 2019.47

 

Incompetence in Data and Processes

Perhaps the most shocking discovery we made when analyzing the data on targeted individuals was the staggering number of errors uncovered during extraction from the official lists. Some mistakes raised numerous questions about the targeting strategies for this extremely important issue and just how seriously their implementation is being taken. 

Some listed names are completely unknown to a wide range of Syrian pundits. It is also unclear how often these lists are maintained and updated; we found 14 listed people who have died, for instance. This could have been a deliberate decision, designed to freeze the assets of the deceased and block access by their heirs, but we were unable to find much information, leaving the matter unresolved.

Also, we found misspelled names that do not match with official records or published sources, like “Sua’amaia Saber Hamcho (Arabic: سعمية صابر حمشو),”48 whose correct Arabic name is سمية (Sumayah). This is different from an individual intentionally misspelling their own name to avoid sanctions, or changing it altogether — like Wasim Badea al-Assad, now Wasim Shahrour, according to recent comments by Ayman Abdel Nour.49 Moreover, some familial connections were so utterly wrong that it made us skeptical of not only the fact-checking process, but the targeting approach altogether. An example is when Mohammad Hamcho was found listed as the brother-in-law of Maher al-Assad on one of the EU sanction lists.50 Hamcho is widely known for serving as a front man for Maher al-Assad, but there is no known kinship relation between them.

 Moreover, for individuals sanctioned by both the EU and US, the birthdates of several individuals do not match between the lists. For example, Dhu Al Himma Shalish’s date of birth is listed as 1946 on the EU list,51 but as 1956 on the US list,52 shedding light on the lack of coordination at the data level. The existence of these “data silos”53 — where datasets are isolated rather than integrated and shared to be accessed by different groups — has a potentially severe impact on the effectiveness of sanctions and the decision-making around them. 

The data strategies adopted by the EU and US should enable effective data integration and coordination. Bridging data silos at the targeting stage can reduce opportunity loss and increase the sanctions' effectiveness. However, while bridging seems an effective mechanism, a study published in 2020 by the global risk consultancy Control Risks54 noticed a major trend whereby the “EU and US are growing apart on sanctions policy,” and predicted that the schism will increase to the point where the EU will seek more autonomy.

We also noticed some logical conflicts. One is that the sanctions do not seem to cascade automatically or follow any sort of hierarchy. For example, some sanctions targeted the entire Syrian army first, then later its 1st Corps. This defies rationality and suggests that some sanctions are probably redundant.

 Finally, we found that the sanctions lists do not include all of the heads of the security apparatus, military intelligence, militia factions, etc. — individuals necessarily involved in oppressing civilians, given their seniority and notoriety. These individuals are very well known to the public. However, most ministers have been sanctioned, including cabinet ministers and ministers of state, even though they tend to play a marginal role in state management compared to the previous group. This finding raises immediate questions about the methodology and selection process for sanctions, which should be more comprehensive and target actual influencers.

 

Ambiguity in Justifications

Although sanctions are usually supported by a justification statement highlighting why an entity was listed, most of these statements are somewhat abstract and do not provide sufficient detail for anyone interested in knowing more. This ambiguity can cause confusion; for example, Syrian Vice-President Farouk al-Shara'a was sanctioned for his involvement in “violence against the civilian population,” despite the fact that he has publicly denounced violence and was barred from public appearances for a long time because of it.55 This is not to exonerate him from any wrongdoing, and there may be other reasons or evidence that led to his sanctioning, but we believe this information should be shared to prevent speculation.

Such ambiguity in justification has multiple impacts, including the growing belief among ordinary Syrians that sanctions are cherry-picked, biased, and reactive to public outrage in the West, rather than a means for accountability and democratic transition. Sanctions are viewed as a way for Western countries to avoid the embarrassment of complete inaction; this belief is reinforced when the tactic is not used in conjunction with other policy levers that might result in an actual change in behavior by the regime. 

Another impact of vague justification statements is that they feed the simplistic belief by most observers that Western sanctions hurt only civilians, when in fact sanctions are like a sledgehammer, hurting the regime as well as the people. It is difficult to track any behavioral change without the particular details of the tactics used by businessmen to help the regime evade sanctions, and companies' complex ownership structures used by key regime figures to manage their foreign accounts. Syrian organizations, grassroots movements, and watchdog groups that use open-source intelligence tools also have trouble monitoring and tracking the impact opaquely-justified sanctions have on targeted entities.

Ambiguity about the sequence of criminal acts that led to an entity being sanctioned may give the regime a means to not only evade sanctions, but to mislead the listing process, putting selected low- or non-criminal individuals into the spotlight as blinds for the real perpetrators. This tactic also provides a tool for the regime to manage internal rivalries, using global sanctions as a means of blackmail and scapegoating. Moreover, sanctions aimed solely at "little fish" may unintentionally tip off "big fish," giving them time to change their illicit tactics. 

Finally, such ambiguity helps feed regime propaganda and attempts to deflect the attention of the Syrian people from the more relevant causes of their struggling economy (e.g., corruption, aid diversion, mismanagement, etc.).

An Assessment of Sanction Impacts as a Tactic

This section assesses sanction impacts in general and their effectiveness in achieving their intended goals. Efforts to answer this question are not new; some of the published studies on the feasibility of economic sanctions date back to 1925.56 Various research papers like J. Galtung,57 D. Seekins,58 and P. Wallensteen59 concluded that economic sanctions are not overly effective in achieving the desired changes. G. Lopez60 concluded that, especially in authoritarian regimes, sanctions lead to suffering and economic hardships for citizens far more often than to any political change.
Relatively newer research uses more quantitative analysis and game theory. In a paper published in 2019,61 Dursun Peksen modeled economic sanctions using a game-theoretic approach to simulate their effectiveness. He argued that sanctions’ success against dictatorships varies based on the type of targeted autocracy. 

Single-party and military regimes are less likely to surrender to foreign pressure, as they can effectively use various repressive approaches to tolerate the costs of the coercion. Sanctions against personalist62 regimes are more likely to be effective, however, since there is less institutional capacity to support the leader. It is difficult to label the Syrian regime specifically as personalist, because it still has reasonably functional civil and military institutions.

George Tsebelis published an interesting paper in 1990,63 which modeled six scenarios of sanctions driven by game theory concepts. He arrived at counter-intuitive conclusions, which he called the “Robinson Crusoe fallacy.” While acknowledging the shortcomings of applying game theory in policy analysis — given its tendency to be abstractive, the insufficiency of data points, the challenges of quantifying variables and establishing causality, etc. — the author introduced an approach that aligns nicely with policy analysis techniques. 

The two main findings reported by Tsebelis are:

  1. The six scenarios, driven by game-theoretic models, showed that, contrary to conventional wisdom that changing the incentives of one player will modify his behavior, in reality it modifies the behavior of his opponent. In other words:
    •  To decrease the frequency of violations, the sender country (applying the sanctions) must modify the payoffs/incentives. An example of payoffs is the economic cost of applying sanctions given that violations are committed.
    • To decrease the frequency of sanctions, the target country (being sanctioned for violations) must modify their payoffs. An example of payoffs is the diplomatic costs of harmonious/strained relations between sender and target. 
  2. Conventional analysis examines sanctions from the perspective of the target country. It ignores the fact that sanctions and violations are the outcome of two-player interaction, a game between rational players trying to promote their own goals, both capable of behavioral change, rather than “a simple decision against nature.” This ignorance of that fact is what Tsebelis calls his “Robinson Crusoe fallacy.” 

​One main caveat of Tsebelis’ paper is that it uses a mixed payoffs/incentives model, making it difficult to attribute the change in one country’s behavior to the modification of a single action; rather, a collective change in actions/policies is needed to reach equilibrium. In the case of the Syrian regime, it appears Assad is doubling down on violations and sticking to his defiance, hoping that the US/EU will change their actions in the end (i.e., the cost of sanctions will no longer be in US/EU interests and the benefits of harmonious relations with the regime will become more feasible). 

This finding aligns with the argument made by Joshua Landis and Steven Simon,64 who criticized the Trump administration's sanctions (specifically, the Caesar Act) targeting the construction, electricity, and oil sectors in Syria — making it impossible for even non-US aid organizations to contribute to the reconstruction of the country (specifically in the “small-scale infrastructural rehabilitation”).65 They concluded that the assumption these sanctions will force the Syrian regime to change its incentives, where “Assad will freely accept the UN plan—which calls for fair elections, a new constitution, and credible, inclusive and non-sectarian governance,” is “disconnected from reality.”66

A more balanced policy paper, in terms of asking both senders and target countries, rather than just one or the other, to change their approaches was published by the Syria Justice and Accountability Centre (SJAC) in June 2020. It calls on both the US/EU and Syria to change their payoffs and incentives, especially during the COVID-19 crisis.67 The paper recommended that the US/EU should:

  • Inform exporters of essential medical equipment that humanitarian endeavors are exempted from sanctions
  • Temporarily exempt dual-use products
  • Ease the restrictions on remittance payments to Syria
  • “Negotiate a relief mechanism modeled after the Swiss-Iran humanitarian channel”

​​At the same time, the paper recommends that the Syrian regime reduce the impact of sanctions and enhance its relations with the West by freeing political detainees, allowing access to prisons, and sharing COVID-19 data with the World Health Organization.

We will take a simpler approach in assessing the effectiveness of sanctions, as we believe the empirical literature review cannot be relied upon due to various caveats like tiny sample size, time horizon issues, the inability to establish causality, and many others. Our approach is more qualitative and discusses effectiveness in terms of negative and positive impacts.

 

Positive Impacts

We grouped the positive impacts into four main points:

  1. Sanctions coerce entities to change behavior and/or accept compromises. To understand the achievement levels of this goal, we studied the delisted entities. Foreign government entities included the Turkish ministries of Defense and Natural Resources (and their ministers, Hulusi Akar and Fatih Donmez) that were both sanctioned and then delisted in October 2019 under EO 13894 for “Contributing to the Situation in Syria.”68 Private-sector entities Blue Marine Shipping Agency and Skirron Holding AG (both in Switzerland) were sanctioned under EO 13582 for conducting economic transactions with the regime, but were then delisted three days later.69 These two groups changed their behavior after the sanctions were imposed, and the change in behavior prompted the sanctions to be lifted. Coercing sanctioned entities into behavioral changes in this case is better than the option of no sanctions at all. It is important to note that the success in reaching desired change partly depends on where the sanctioned entities are located and where they do most of their business. For example, the entities in Switzerland likely did not want to jeopardize their ties in EU and US markets, so they complied. An actor with limited involvement in these areas may not be scared off by sanctions, however. 
  2. Sanctions have given the Assad regime and its backers (Iran and Russia) one more reason to seek a political settlement to the conflict. This cannot be overlooked. The regime does not want to remain broke forever, while Russia and Iran want both an exit from the Syrian quagmire and an opportunity to benefit from the political settlement (military bases, reconstruction, financial benefits, etc.). Unilateral economic sanctions have never, on their own, led to the collapse of a regime. Yet in some cases they can at least cripple the targeted individuals and entities and make it difficult for them to get away with atrocities. 
  3. Sanctions are a deterrence tool, sending explicit signals to individuals and entities involved with sanctioned targets that they are being watched and could be next, if they normalize their relations with targets or haven’t disowned any covert or overt activities. For example, foreign companies’ involvement in reconstruction activities on expropriated (regime-seized) land in Damascus is virtually non-existent primarily due to US/EU sanctions. While this tool definitely works, as reflected in the example above, it often doesn’t receive enough credit because we can’t see its impact in action (i.e., we don’t know when a company decides to not take action in Syria; we only know when they take action). Since it has recently become easier to implement secondary sanctions under the Caesar Act, the effectiveness of this objective can be better utilized.
  4. Sanctions send a message to other countries that mass killings and torture cannot be carried out with absolute impunity. Although Assad’s regime has raised the bar to a level that encourages other dictatorships to commit what would once have been considered unimaginable without being forcefully stopped by Western powers, sanctions send a message to other dictators that the West may not completely overlook their actions.

 

Negative Impacts

When assessing the negative impacts of sanctions, it is important to distinguish between negative impacts caused by sanctions, and those that simply correlate with them. For example, the multiple sanction regimes have undoubtedly contributed to Syria's economic distress. However, despite the regime's messaging, the sanctions are not the only reason for that distress; the Caesar Act came into effect after years of institutional corruption, a war economy, aid diversion, and mismanagement, all exacerbated by the ramifications of the COVID-19 pandemic and the banking crisis in Lebanon. Some would argue that even if the regime wanted to import some goods targeted by the Caesar Act, it is not clear if it has the funds to do so. How easy would it be for the regime to secure a loan from foreign banks even if there were no sanctions, given its low credit profile?

We grouped the negative impacts into five main points:

  1. On the humanitarian front, the sanctions have had a negative impact on Syrian non-governmental organizations (NGOs) operating within and outside Syrian borders. In a report published by IMPACT Civil Society Research and Development,70 various Syrian organizations operating in France, the UK, Germany, Turkey, and Lebanon shared the challenges they face. Many have had their bank accounts closed, were blocked from opening new ones, and were not allowed to send or receive wire transfers. Some were forced to transact only with EU-based banks. These measures usually included no stated justification and were attributed to over-compliance; in a few cases, stated justifications ranged from a Syrian being a member of the NGO’s board of directors to a vague excuse that the situation in Syria is unstable.
  2. Sanctions have caused huge problems for Syrian civilians living abroad. Over-compliance tracked them in various countries around the world, closed their accounts, and prohibited them from opening new ones, often without explanation, all leading to a chilling effect whereby no one wanted to transact with them, for no apparent good reason.71
  3. There is near-total academic consensus that, regardless of type, economic sanctions have a negative impact on national economies. This is especially true in countries where dictatorship is mixed with monopoly, crony capitalism, and a strongly skewed distribution of wealth. In Syria, individuals and entities with greater access to resources and power are more able to endure the sanctions, while small- and medium-sized enterprises, especially those not involved with the regime, are more likely to fail as access to resources becomes exclusive. 
  4. Sanctions have blocked rehabilitative services in areas not controlled by the regime. In rebel-held territory in northwestern Syria, besides making it almost impossible for international NGOs to contribute to “small-scale infrastructural rehabilitation,”72 the Caesar Act recently blocked technology resources there, including Google Workspace (formerly Google Business Suite), a suite of applications used by many Syrian civil society organizations (CSOs) and NGOs.73 Western technology bans on Syria are not new, but it has never been this extensive. It includes many online services in which technology is either at the core (e.g., Oracle Java and Google Chrome),74 or operates as a business enabler (e.g., freelance job sites Freelancer and Upwork).75 The list is constantly growing to include popular platforms like Netflix and Zoom as well,76 but the surprising fact about Google Workspace is that the Internet cables in areas outside regime control are connected to networks in Turkey or Iraq, not Syria.77

 

Philosophies of the Engaged Parties

The final assessment of this study will try to understand the sanctions from the main target’s point of view as well as from that of the Western countries imposing them. In March 2021, 14 Syrian dissident organizations published a letter78 asking Bashar al-Assad to suspend the US/EU sanctions himself by fulfilling certain criteria of the Caesar Act, like releasing political prisoners and establishing a structured process for accountability. Like every other attempt over the years of conflict, this was essentially ignored by Assad.

We believe Assad’s choice not to concede to sanctions is rational, as the negative impacts of a political settlement are greater for him than those imposed by sanctions. Open elections would mark the beginning of the end of the regime, as it is not popular with the citizenry. A survey conducted in Damascus in late 2020 by the Operations and Policy Center showed that nearly two-thirds of respondents wish to leave the country (63.5%).79 Even people in Assad’s most cared-for areas are sick of living under his rule.

Without the protection of his office, Assad would likely be under threat all the time, whether in Syria or abroad. Justice is much more likely to be served on the weak; he might face the same fate as Adib Shishakli, a former Syrian dictator who was assassinated on September 27, 1964 in Brazil by Nawaf Ghazaleh, a Syrian who sought revenge for the death of his parents, killed in Shishakli’s military operation against Jabal Druze. Alternatively, he could be brought to justice despite all the assurances, in a similar scenario to Augusto Pinochet, the former Chilean military dictator, who was indicted and arrested in the UK under the principle of universal jurisdiction.80

As for Western politicians, we believe they know by now that sanctions alone are not enough to compel the Assad regime to accept a fair settlement to the conflict. However, they also know that incentivizing Assad’s backers and exerting enough additional pressure on them to trigger a behavioral response is not cheap. We must therefore conclude that, above all, sanctions are to Western politicians little more than a fig leaf to cover their lack of genuine interest in finding a solution to the Syrian crisis in the face of domestic pressure to end the misery of the Syrian people within and outside the country, and a reflection of their political weakness in Syria.

Policy Recommendations

The current model of sanctions is suboptimal, with a high likelihood that sanction targets can use evasive strategies to avoid any actual harm. We believe this would still hold even when, as recommended by Zaki Mehchy and Rim Turkmani,81 easing/lifting sanctions is applied on meso-level actors: small and medium-sized independent business and CSOs that would receive targeted support to lessen the suffering of people.

We recommend three main changes to US/EU sanctions policy, keeping in mind that such changes need to be, as much as possible, made as a whole and not in parts:

  1. First, scrap all forms of country-based and sector-based sanctions, especially on financial transactions, as their harm outweighs the benefit, even for ordinary Syrians in the diaspora and opposition-held areas. This should be done in exchange for gains, such as releasing prisoners. Instead, expand the use of travel bans and asset freezes.
  2. Implement a more active whole-of-Syria policy by threatening more sticks and offering more carrots than in the current framework. Avoid making sanctions the primary policy tool, as this tactic is unlikely to result in behavioral change. 
    • Carrots: Provide incentives for Assad’s allies to pressure him into compromising or disposing of him, by demonstrating that he remains the primary impediment to their own interests. Incentives could take the form of reconstruction and concessionary loan promises redeemable upon Assad’s removal from power.
    • Sticks: Expedite and facilitate legal action taken against regime officials and its enablers abroad in Western and international courts.
  3. Improve the effectiveness of sanctions:
    • Use secondary sanctions more actively, especially on less-entrenched individuals where a change in behavior is more likely.
    • Go beyond the tip of the iceberg; target the deep networks of the regime. Sanction all heads of security apparatus, military intelligence, militia factions, and businessmen affiliated with the regime.
    • Establish a reward program to incentivize Syrians, especially those living in-country, to speak out and uncover individuals involved in the regime’s crimes. Rewards can be either financial or the offer of asylum.
    • Involve Syrian organizations, grassroots movements, and watchdog groups in collecting evidence and mapping the power structure of the Syrian regime, in order to minimize and correct errors in the current sanction lists.
    • Bridge the data silos and increase coordination between the US and EU to enhance sanction impacts.
    • Improve transparency and communication with the public to enhance the impact of sanctions: Why exactly are some people listed? Why are they delisted? Why was the Caesar Act applied to only four individuals?
    • Adopt an agile re-evaluation and review process for imposed sanctions, in order to quickly weigh their cost-effectiveness and make corresponding adjustments. This will minimize the effects of misapplied sanctions that lead to unintended consequences. This aligns to some extent with Mehchy and Turkmani’s recommendation of establishing a monitoring system for sanctions.82

 

Wael Alalwani is a data scientist and researcher in financial crimes analytics originally from the city of Hama, Syria. He holds a Masters in Artificial Intelligence from King Abdullah University of Science and Technology (KAUST). 

Karam Shaar holds a PhD in Economics from Victoria University of Wellington. He is a non-resident scholar at the Middle East Institute and the lead researcher at the Operations & Policy Center. Follow him on Twitter: @karam__shaar. The opinions expressed in this piece are their own.

August 2021, Policy Paper 2021-28

 

Acknowledgement

The authors would like to thank Joseph Daher and Zaki Mehchy for their valuable comments and suggestions to this paper. We also thank Ammar al-Nakeeb for his assistance in analyzing the data and assessing the impacts of sanctions on humanitarian aid.


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  81. Zaki Mehchy and Rim Turkmani, “Understanding the Impact of Sanctions on the Political Dynamics in Syria” The London School of Economics and Political Science, January, 2021, http://eprints.lse.ac.uk/108412/1/CRP_understanding_impact_of_sanctions_on_political_dynamics_syria.pdf
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