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U.S. GOVERNMENT
INFORMATION
GPO
FINANCIAL SERVICES AND GENERAL GOV-
ERNMENT APPROPRIATIONS FOR FISCAL
YEAR 2023
U.S. SENATE,
SUBCOMMITTEE OF THE COMMITTEE ON APPROPRIATIONS,
Washington, DC.
NONDEPARTMENTAL WITNESSES
[CLERK'S NOTE.-The subcommittee was unable to hold hearings
on nondepartmental witnesses. The statements and letters of those
submitting written testimony are as follows:]
PREPARED STATEMENT OF THE AMERICAN FRIENDS SERVICE COMMITTEE (AFSC)
Chairman Van Hollen, Ranking Member Hyde-Smith, and Members of the Com-
mittee, thank you for the opportunity to submit testimony. My name is Daniel Jas-
per and I am the Asia Public Education and Advocacy Coordinator for the American
Friends Service Committee (AFSC). We are a peace and social justice organization
that has worked for over a hundred years to address the root causes of violence and
conflict throughout the world. We appreciate the opportunity to address the use of
sanctions before the subcommittee today, as this foreign policy tool now serves as
a primary response to geopolitical conflict. Specifically, my testimony addresses (1)
report language addressing the need for the Government Accountability Office
(GAO) to conduct impact assessments on comprehensive sanctions regimes, and (2)
the need for the Treasury Department's Office of Foreign Assets Control (OFAC) to
conduct regular and comprehensive reporting on licensing procedures.
The urgency and importance of conducting impact assessments on comprehensive
sanctions regimes cannot be understated. In 2021, The Treasury Department's sanc-
tions review found that sanctions designations have risen from 912 to 9,421 in the
last two decades, representing an increase of 933%.1 However, despite this accel-
erating rate of usage, government agencies have indicated that the impact of sanc-
tions is often unclear.
According to a 2019 GAO report, implementing and relevant agencies only con-
duct ad hoc assessments and do not monitor the overall effectiveness of existing
sanctions programs in achieving broad policy goals. The report found that officials
only informally evaluate the overall efficacy of these measures. However, given the
immense impact of sanctions on ordinary civilians and the global economy, informal
evaluations are grossly insufficient. Notably, officials indicated that one major rea-
son for the lack of comprehensive assessments is that there is no policy or require-
ment for this type of analysis.2 It's clear, then, that until Congress enacts such a
policy, the executive branch is unlikely to undertake such critical assessments on
its own accord.
Throughout AFSC's more than one hundred-year history, the organization has ac-
companied countless communities under sanctions regimes and borne witness to the
varied impacts of these measures. Our organization, for instance, was among the
first to support South Africans in their call to sanction the apartheid regime. While
12021 Sanctions Review. U.S. Department of Treasury, Oct. 2021, https://home.treasury.gov/
system/files/136/Treasury-2021-sanctions-review.pdf.
2Economic Sanctions: Agencies Assess Impacts on Targets, and Studies Suggest Several Fac-
tors Contribute to Sanctions' Effectiveness. U.S. Government Accountability Office, Oct. 2019,
https://www.gao.gov/assets/gao-20-145.pdf.
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