In his waning days in office, President Joe Biden chose to take his first and only trip to sub-Saharan Africa to, among other things, announce funding for the multi-country Lobito Corridor rail project. The idea is to counter Chinese investment in minerals and infrastructure across the continent. In committing to the project, he declared, “Africa is the future.”
That’s nice to hear, but such declarations need more substance to them, lest it become – if it hasn’t already – an empty cliché. That means many more examples of U.S. and allied investments and forms of engagement across the continent (and not solely in a scramble for minerals access but in other sectors). It also requires far more willingness to establish clear and principled rules of engagement, with costs imposed when those are violated, especially by Chinese and other actors.
So as most everyone in Washington (and the globe) focuses on how the next Trump administration will deal with the massive web of sanctions in place against Russia, how it will strengthen its “maximum pressure” approach on Iran (and perhaps Venezuela and Cuba), and, most intriguing of all, whether and how it will rev up actions against China, it is worth adding to the mix how the next Trump administration considers use of sanctions across the African continent. If the past is at all prologue, these will be worth watching not only for how they impact some of the most challenging — and promising — contexts on the globe, but potentially as some of the more focused and effective sanctions measures and strategies.
In sum, the Biden administration did not make optimal use of the sanctions tool when dealing with conflicts and crises in Ethiopia, Sudan, Eastern Congo, or across the Sahel. Although we can never know whether sanctions would have changed course, we do know the situations in each place have become increasingly problematic and concerning, rather than less so. There were also few actions taken in contexts with less violence but where sanctions could have played a helpful role in disrupting harmful and entrenched networks or imposing costs on those who violate human rights or democratic institutions. Similarly, in the tenor of the Angola trip, sanctions that could have helped to counter strategic competitors that often rely on bribery and corruption (such as in the natural resources/critical minerals and the procurement/construction sectors) were also left on the table.
If the Trump administration is able to move away from these obstacles and take a more direct approach with respect to sanctions, it may open up other opportunities to advance broader policy, national security, and even economic objectives, such as competition with China, critical minerals and other natural resource supply chain security, and even immigration.
To be clear, as I have argued recently here at Just Security, sanctions for sanctions’ sake rarely have the desired impact. Rather, sanctions are most effective when integrated into a holistic strategy and part of a broader set of tools, rather than just a reflexive or reactive choice. There can be a range of consequences to any sanctions action in a specific country context, and the more clearly those are thought through and prepared for, the more beneficial to the policy. There are also broader concerns, e.g. that the overuse of sanctions may drive countries away from the U.S. dollar and financial system, but that continues to be more theory than reality, especially as natural resources continue to be denominated in dollars, as the most recent SWIFT data shows. Moreover, establishing clear lines and rules of the road for engaging with the United States in the present can just as easily strengthen the U.S. role in the future as weaken it. In the end, the key is to ensure that, once all of this thinking and preparation is done, decision-makers take the difficult steps and act, rather than find reasons to keep waiting.
The Trump I Record
From 2017 to 2020, the Trump administration imposed a series of sanctions actions related to the Democratic Republic of Congo (as part of a high-level push to ensure that warlord Joseph Kabila did not run for a third term) and South Sudan (to ease the then-raging civil war). The administration also used sanctions to establish accountability for broader corruption and human rights issues that made significant impact in countries like South Africa (related to the Gupta clan) and The Gambia (related to former dictator Yahya Jammeh). This is not to suggest there were no concerns with the Trump administration’s policies related to Africa, and there were undoubtedly other critical actions that were not taken. Overall, though, the use of the sanctions tool during those years was constructive and forward-leaning in advancing policy in key contexts.
Trump II — Overcoming Biden Administration Misgivings
To be sure, the Biden administration did take some important steps on sanctions related to Africa, and there is still time for more. For example, corruption and human rights-related sanctions in Liberia were well-received by the population. Elements of the sanctions efforts in Sudan and to counter Russia’s Wagner Group proved useful, at least as temporary disruptions, which is often the best outcome. And an unprecedented termination of a stale sanctions program in Zimbabwe and transition of key Zimbabwean targets to the Global Magnitsky program helped to focus attention on the key areas that sanctions could actually impact and to remove an obstacle to regional policy and public diplomacy. The strong action taken on Dec. 9 against a “Gold Mafia” network reinforced the type of actors the United States could address – those greedily stealing from a struggling country’s coffers and enabling corrupt leaders while living lavishly elsewhere.
But despite these positive actions, a number of persistent misunderstandings and misconceptions dogged the potential to impose stronger and more impactful actions, not just to advance U.S. interests in various African contexts but as a way of contributing to broader global policy. Here are some ways the next Trump team can correct course and perhaps pick up at least this aspect of where they left off:
- See sanctions as more than “name and shame.” Many policymakers still see sanctions mainly as a “name and shame” tool. Although that can be one result, it undersells the role of sanctions and can lead to poor decision-making about when and on whom to use them. This often belies a lack of understanding of how the global financial system works, the role of the U.S. dollar in foreign markets, or at times, just insufficient training or exposure to good uses of the tool. The Trump administration should ensure there are officials in place who understand the financial system and the economic impact sanctions can have over time; his announced nominee for secretary of state, U.S. Senator Marco Rubio and national security advisor-designee U.S. Representative Michael Waltz, do understand sanctions well, and it will be essential that those in charge of Africa policy have similar experience.
- Re-evaluate the importance of “access.” Policymakers and diplomats too often think mainly about the short-term, disruptive results of sanctions, such as the temporary or even long-term disruption in diplomatic “access” when inevitably leaders in the target country get upset. If access is prioritized in the face of policy failures, it is important to ask precisely what value the access is providing, especially in countries where leadership take actions more seriously than threats. That is, short-term access disruption may actually lead to more serious relationships over the longer term because the consequences are clear for the counterparts. And if sanctions can help establish clearer and firmer lines for the price of access to the United States, then that will be a positive shift and one the Trump team is more likely to adopt.
- Have patience and vision in order to have impact (and stick with a strategy). When sanctions were imposed during the Biden years, policymakers and their senior aides — in both the Executive Branch and in Congress — quickly asked whether they had “worked,” often meaning in a very narrow sense of immediately thwarting the targeted action. When those sanctioned were able to continue fighting or conducting business, the verdict would quickly be reached that the sanctions had not “worked,” leading to decisions to put their future use to the side. This ensures a self-fulfilling prophecy, as sanctions work best when they are advancing a clear policy and strategy and when the targeting unfolds in a steady, consistent, and persistently escalatory manner. That means staying with the tool as targeting gets closer to the center of a specific concern, even as, again, it may disrupt access or messaging. Following this course also requires a consistent and clearly outlined policy strategy, which the Trump team will have to set early on.
- Be willing to impose costs for corrupt and abusive business practices. When there is understanding of the potential economic impact, there can be a reluctance to counter high-level officials in a government or business sector of a country where the United States seeks to promote investment. The belief is often that, if sanctions are imposed, it will mean the whole market will be seen as off limits by Western firms, and/or that the host government will simply turn away from Western investment and into the arms of China, Russia, or others. This was truer in the past where comprehensive embargoes were used in contexts such as Sudan until 2017; in a world of focused and targeted designations, it is much less the case. In particular, corruption, human rights and labor rights abuses, and subversion of the rule of law perpetrated by third-country companies that result in an out-muscling of American or responsible firms should not be tolerated, not least because they harm the people of the affected country as well as U.S. interests, and sanctions can be an important and targeted response. This, again, is an approach that the Trump administration will likely understand, especially if they want to build on the Lobito rail project and expand the number of U.S. investments in markets that are often rife with corruption.
Overall, African leaders in the public and private sectors remain consistently interested in responsible investment, American or otherwise. Rather than drive business away, if targeted and messaged clearly beyond high-level principles, sanctions can set the expectations are for U.S. and other responsible investment, and simultaneously help to establish a more level playing field for both policy and business interests. Countering strategic competition requires direct and proactive investment and engagement, but also clear and enforceable standards.
Africa policy will likely remain further down in the headlines during the second Trump administration, as it did during the first. But by following these principles, the Trump team can again quietly re-establish the role sanctions can play in advancing that policy and help to deliver on the African future that has been promised for far too long.
– Brad Brooks-Rubin is a partner at Arktouros, a boutique law firm specializing in sanctions, anti-money laundering, and regulatory advice. He previously was a Senior Advisor in the Office of Sanctions Coordination at the U.S. Department of State, and earlier served as Policy Director and then Managing Director at The Sentry. Published courtesy of Just Security,
