As tourists complete their strolls to the White House from the east along Pennsylvania Avenue, they pass a relatively unremarkable, columned office building that overlooks Lafayette Square—oblivious that, behind its walls, bureaucrats are quietly inflicting poverty, illness and death on innumerable innocents around the world.
The Freedman’s Bank Building doesn’t house CIA or Department of Defense officials, but rather the U.S. Treasury’s little-known Office of Foreign Assets Control (OFAC). Instead of orchestrating airstrikes or insurgencies, these bureaucrats impose mass suffering via economic warfare, collectively serving as the tip of the spear that is America’s ever-expanding economic sanctions regime.
The term “banality of evil” was coined by intellectual Hannah Arendt after she observed the 1961 trial of Adolf Eichmann, the Nazi official who, from his post atop the inscrutably-named Office IV B 4, oversaw the grim logistics of funneling Jews into German concentration camps.
Arendt said she was struck to find Eichmann “neither perverted nor sadistic,” but “terrifyingly normal.” Rather than a rabid ideologue or psychopathic antisemite, Arendt found herself observing a boring bureaucrat whose diligent performance of his assigned duties was largely motivated by a mere desire for career advancement. “The deeds were monstrous, but the doer—at least the very effective one now on trial—was quite ordinary, commonplace, and neither demonic nor monstrous,” Arendt later wrote.
Arendt’s characterization sparked great controversy. In subsequent decades, some historians have challenged her assessment of Eichmann, and philosophers have wrestled with her proposition that one can do evil without being evil.
Whatever the appropriateness of Arendt’s application of “the banality of evil” to Eichmann, it’s safe to say the individual employees of OFAC—mostly lawyers—similarly aren’t perceived by people around them as malevolent. If you live in the vicinity of the capital, an OFAC worker might be the congenial coach of your child’s soccer team or a friendly face at a volunteer event.
However, regardless of their personalities and sincere convictions that they’re engaged in public service, the stark reality is that many OFAC employees spend their workdays carrying out the mass victimization of people who’ve done no harm to the United States or its citizens. To paraphrase Arendt, these people may be quite ordinary, but their deeds are monstrous.
Considering, just for starters, the direct and indirect effects of the invasion of Iraq, the Pentagon’s Central Command has arguably caused the most twenty-first century harm to innocents of any organization in the world. However, staffed with a mere 300 or so bureaucrats, OFAC is surely the leader on a harm-per-employee basis.
Sanctions are often perceived as a welcome alternative to war. In fact, they are merely a different form of war—one that can also produce dead bodies and misery on a grand scale, with the vast majority of the victims having no responsibility for their governments’ supposedly offending actions. (While sanctions are also deployed against terrorists and drug cartels, my focus here is on economic warfare waged against entire countries.)
The power of American sanctions springs from the US dollar’s domination of international trade and finance. As The Washington Post recently explained:
“To deal in dollars, financial institutions must often borrow, however temporarily, from U.S. counterparts and comply with the rules of the U.S. government. That makes the Treasury Department, which regulates the U.S. financial system, the gatekeeper to the world’s banking operations. And sanctions are the gate.”
Sanctions come in a variety of flavors, including the freezing of assets, barring of financial transactions, and blocking of exports or imports. There are also “secondary sanctions” aimed at non-American parties who dare to conduct business with a sanctions target.
Though they’ve long been part of the American arsenal, sanctions use rose sharply during the 1990s and exploded after 9/11 with the “war on terror” and the accompanying surge in U.S. foreign interventionism and regime-change campaigns. In 2000, there were 912 designated entities; by 2021, there were 9,421.
Via the International Emergency Economic Powers Act of 1977, presidents have broad, unilateral power to impose sanctions to “deal with an unusual and extraordinary threat” to national security. The determination of what constitutes such a threat also rests in the president’s hands, and they unsurprisingly apply an expansive interpretation.
Sanctions can also originate in Congress. Eager to bolster their national security credentials and curry the favor of interest groups like pro-Israel organizations, legislators introduce them with abandon: In the 117th Congress that ended in January 2023, members introduced more than 350 sanctions bills.
“It is way, way overused, and it’s become out of control,” former Senate Foreign Relations Committee staffer Caleb McCarry told the Post, casting OFAC employees as victims. “They are good professionals who have all this political work being shoved on them. They want relief from this relentless, never-ending, you-must-sanction-everybody-and-their-sister, sometimes literally, system.”
Washington’s bipartisan sanctions compulsion surely causes OFAC employees some workplace stress and perhaps a few skipped happy hours. For countless innocents in targeted countries, OFAC-enforced sanctions cause everything from unemployment, ruined career aspirations, financial insecurity and poverty to depression, hunger, disease and death.
Lest you think that harm to civilians via economic warfare is akin to unintended “collateral damage” in conventional warfare, champions of sanctions often make clear that the infliction of misery on civilians is a central aim:
- “Denying money and supplies to Cuba [will] bring about hunger, desperation and overthrow of [its] government.”- Deputy Assistant Secretary of State Lestor Mallary in a 1960 memorandum.
- “Iraqis will pay the price while [Saddam Hussein] is in power. All possible sanctions will be maintained until he is gone.”- George H.W. Bush’s then-deputy national security advisor Robert Gates.
- “[Sanctions] make people suffer. They hurt. They can destroy.”- Former OFAC director of global targeting Robert McBrien, seemingly speaking not with remorse, but awe.
- “Critics [have] argued that these measures will hurt the Iranian people. Quite frankly, we need to do just that.”- Rep. Brad Sherman.
