On 27 October, US Deputy Treasury Secretary Wally Adeyemo gave remarks at the Royal United Services Institute (RUSI) in London, UK, regarding recent developments in America’s international sanctions regime.

The speech, which was followed by an open-forum discussion, came after the US Department of the Treasury announced new and more stringent sanctions on Hamas and associates aiding Hamas’ operations.

The deputy secretary spoke at length about the need for international cooperation in further enforcing ongoing sanctions against Russia that began after its illegal annexation of Crimea in 2014 and increased significantly following the 2022 invasion.

After entering office in 2021, Adeyemo oversaw a review of the department’s post-9/11 sanctions policies to determine the effectiveness of such efforts in various parts of the world.

The review covered the rise of non-traditional banking tools in this period such as e-banking, payment apps like Venmo and PayPal, and the emergence of Bitcoin and other cryptocurrencies as a form of legitimate payment to potentially fuel regimes.

The results of this review informed the development of both the sanctions placed on Russia in 2022 and the new restrictions placed on Hamas and its affiliates this week. These restrictions are organised via the Office of Foreign Assets Control of the Treasury Department.

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The deputy secretary focused on the importance of US cooperation with its international partners, especially the UK, the EU, and other European states.

He emphasised EU cooperation not only with individual states but with bloc-wide institutions and regulators and highlighted the need for continued joint US-UK-EU efforts to prevent small and medium enterprises from intentionally or unintentionally supplying Russia.

Additionally, he stressed the role of larger private sector banks and corporations in maintaining due diligence to prevent financing illicit activities.

As the sources of sanctions evasion and terrorist financing are international, only an international regulatory approach can prevent bad actors in the globalised financial system.

The deputy secretary also noted the Biden Administration’s successful effort within UN Resolution 2664, which created a humanitarian aid ‘carve-out’ that allows some organisations to deliver humanitarian relief without worry of violating the sanctions of a regime.

In particular, this UN resolution allows for aid to enter Gaza despite the increased sanctions activity against Hamas.

The UN resolution will also enable foreign aid workers to deliver basic supplies to those in other sanctioned regimes.

After his remarks, Adeyemo answered questions from Tom Keatinge, director of the RUSI’s Centre for Financial Crime & Security Studies.

The deputy secretary specifically criticised Iran and its Revolutionary Guard Corps for their role in supporting Hamas, noting that many senior Iranian officials have been sanctioned alongside Hamas members as a result.

In addition, he discussed the effects of US sanctions on Russia since 2022, noting that the Russian economy has shrunk considerably, complicating the Russian war effort in Ukraine.

The deputy secretary expressed the opinion that Russia’s economy has become centred on its war effort, and American and allied sanctions ensure Western military support to Ukraine is maximally effective.

Adeyemo’s comments demonstrate the Biden Administration’s continued commitment to international cooperation and diplomacy.

His department’s efforts will help to mitigate sanctions evasion and limit the resources available to American adversaries.