RESEARCH REPORT CONVERGENCE - THE EVOLUTION OF TARGETED ZONE SANCTIONS USAGE AGAINST

states; and that threatens the national security, foreign policy, or economy of the United States’.50 In detailing the risks of such entities to the US, the order noted growing challenges around criminal infiltration of govern- ments and the broader financial system, with impacts on democracy, the rule of law, peace and conflict and the functioning of global markets.51 In function, EO 13581 had br. [...] section 2 of this order on any foreign person Use of the counter-corruption and counter-crime sanctions determined by the Secretary of the Treasury, in consultation with the Secretary of State, regimes, and the US sanctions programme more broadly, the Attorney General, and the Secretary of shifted in the late 2010s during the Trump administration. [...] In the DRC, the EU updated its criteria in 2022 to allow for the designation of any actor or entity that ‘exploit[ed] the armed conflict, instability or insecurity in the DRC, including through the illicit exploita- tion or trade of natural resources and wildlife’.190 Moving away from the need for criminal actors to be linked to the financing of armed groups, this substantially expands the range o. [...] For the EU, the issuance of restrictive measures requires unanimity among the 27 member states, mirroring the UN system to a degree.203 However, this unanimity is often easier to gain within the EU, given the closer alignment of member-state interests and the existence of a Common Foreign and Security Policy (CFSP), in which the restrictive-measure process is embedded.204 The employment of restric. [...] STEP 2 PRELIMINARY ASSESSMENT AND NEGOTIATION Member states in the preparatory body assess the evidence underpinning the designation, the impact of the designation on policy priorities of the EU and the impact on policy priorities of the member states.