Recently, Reuters reported that a memorandum from Attorney General Pam Bondi, issued on 5 February 2025, envisaged that the Task Force known as KleptoCapture, started after the Russian Federation’s 2022 invasion of Ukraine to enforce sanctions and target oligarchs close to the Kremlin, will end as part of a shift in focus and funding to combating drug cartels and international gangs.
This is one of the first and most recent indications that Trump’s administration is considering a radical shift in approach to the US sanctions in respect of the Russian Federation.
With the new Trump administration, there is growing speculation about how it might influence the global sanctions landscape, particularly regarding measures imposed against Russian individuals and corporations. The effectiveness of these sanctions is far from uncontroversial in encouraging the Russian government to change its behaviour, however, they remain a key tool. These sanctions, which have been implemented by entities such as the US Office of Foreign Assets Control (OFAC), the UK’s Office of Financial Sanctions Implementation (OFSI), and the European Union (EU), are key tools in countering malign activities and promoting geopolitical objectives. This article examines how a potential shift in US policy under a Trump administration could ripple through these regimes, reshaping enforcement priorities and international coordination.
The Current Sanctions Framework Against Russia
Sanctions against Russia have primarily targeted individuals, businesses, and sectors implicated in activities such as the annexation of Crimea, interference in democratic processes, cyberattacks, and human rights violations. OFAC, OFSI, and the EU have worked to implement coordinated sanctions, focusing on:
- Asset Freezes and Travel Bans: Targeting specific individuals and entities connected to the Kremlin.
- Sectoral Sanctions: Restricting access to key industries such as energy, defence, and finance.
- Export Controls: Limiting the transfer of technology critical to Russian economic and military development.
- Secondary Sanctions: Dissuading third parties from engaging with sanctioned Russian entities.
The coordination among OFAC, OFSI, and EU sanctions regimes has been instrumental in maintaining pressure on Russia, but variations in enforcement and priorities have also emerged.
Trump’s Historical Approach to Sanctions
During his first term, Trump’s administration took a mixed approach to sanctions policy. While sanctions against Russia were often expanded—particularly in response to congressional mandates—Trump himself frequently expressed scepticism about their efficacy and impact on US – Russia relations. Notably:
- Reluctance to Broaden Sanctions: Trump’s administration hesitated to impose certain sanctions required by the Countering America’s Adversaries Through Sanctions Act (CAATSA).
- Emphasis on Bilateral Relations: Trump’s interest in improving relations with Moscow occasionally clashed with the sanctions-first approach favoured by other policymakers.
- Transactional Diplomacy: Trump often viewed sanctions as leverage to negotiate broader deals rather than as standalone punitive measures.
These tendencies suggest that a renewed Trump administration might prioritise strategic flexibility over maintaining the current sanctions framework.
Potential Changes Under a New Trump Administration
A second Trump presidency could usher in several key changes to US sanctions policy, with implications for OFSI and EU regimes such as the following:
- Deprioritisation of Sanctions Enforcement: Trump’s administration may reduce resources dedicated to enforcing sanctions, potentially weakening their overall effectiveness. This could embolden sanctioned entities to seek new avenues for evasion.
- Re-evaluation of Sanctions Criteria: The administration might narrow the scope of sanctions by reassessing criteria for designation. For example, Trump could de-emphasise human rights concerns or political interference as primary justifications.
- Focus on Bilateral Negotiations: Trump could leverage sanctions relief as part of broader deals with Russia, such as agreements on arms control, energy cooperation, or counterterrorism efforts. This approach might lead to selective relaxation of sanctions, particularly in sectors critical to both economies.
- Strained Transatlantic Coordination: A shift in US policy could create friction with the EU and UK, which have emphasised unity in responding to Russia. Diverging priorities might weaken the cohesion of the global sanctions regime.
Whilst Trump’s general position on sanctions is more flexible, if his proposals regarding the end of the conflict are met with resistance by the Russian Federation, it is more likely the Trump administration will double-down on sanctions, making them deeper and wider, targeting more sectors as well as non-Russians that the US administration believes are enablers. Accordingly, one is advised to remain vigilant and keep a close eye on developments.
Implications for OFSI and the EU
The UK and EU have both maintained robust sanctions policies against Russia, particularly following the invasion of Ukraine. However, their frameworks depend on alignment with US measures to maximise impact. A change in US policy could have the following effects:
- Pressure on Unified Sanctions Regimes: Divergence from US policy might force the EU and UK to reassess their approaches, potentially leading to inconsistent enforcement and reduced effectiveness.
- Economic Considerations: European economies heavily reliant on Russian energy could face greater domestic pressure to relax sanctions if the US adopts a softer stance.
- Enforcement Challenges: Reduced US cooperation could hinder the identification and targeting of sanction evasion networks, complicating enforcement for OFSI and the EU.
Broader Geopolitical Considerations
Trump’s foreign policy approach often emphasised a transactional, America-first perspective. His administration may prioritise relations with other strategic rivals, such as China, over maintaining pressure on Russia. This shift could alter the global balance of power and influence, with Russia potentially exploiting reduced sanctions pressure to strengthen its economy and geopolitical influence.
Additionally, allies in Eastern Europe, such as Poland and the Baltic states, might feel vulnerable to a less confrontational US stance toward Russia, prompting calls for increased NATO commitments or independent sanctions measures.
Conclusion
The return of President Trump to the White House raises significant questions about the future of sanctions against Russian individuals and corporations. While it remains uncertain how his administration will navigate this complex policy area, historical tendencies suggest a shift toward selective relaxation and bilateral negotiations. Such a shift could challenge the cohesion of the global sanctions regime, complicate enforcement, and reshape geopolitical dynamics.
For policymakers and businesses operating within OFAC, OFSI, and EU frameworks, the new Trump administration underlines the need for vigilance and
adaptability. Understanding policy shifts and their ramifications will be critical in navigating the uncertain sanctions landscape ahead.
