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[1] United Nations Human Rights Council. (2021). Unilateral coercive measures: notion, types and qualification (Report of the Special Rapporteur on the negative impact of unilateral coercive measures on the enjoyment of human rights, A. Douhan, A/HRC/48/59). https://undocs.org/A/HRC/48/59. “15. The Special Rapporteur regrets that the situation noted in her previous report to the Human Rights Council regarding the expansion of the number, scope and grounds of unilateral sanctions has not improved.9 In fact, the number and scope of sanctions has expanded further, while the extraterritoriality of unilateral sanctions, the application of secondary sanctions and the development of national civil and criminal penalties for violations of sanctions regimes result in overcompliance. More and more States have started to apply counter-sanctions or develop mechanisms to resist the extraterritorial consequences of sanctions.10 16. The Special Rapporteur notes that the specific forms of pressure applied by individual States or groups of States have changed and are still changing. States apply various forms of unilateral sanctions in pursuit of common goods, thereby transforming exceptions in international relations into ordinary practice. 17. The Special Rapporteur underscores that, given the focus of the present report on the terminological and qualification aspects of the application of sanctions, the term “unilateral sanctions” is used here irrespective of their legality or illegality and refers to any means of pressure applied by States or international organizations without or beyond the authorization of the Security Council. 18. The Special Rapporteur recalls that, given the absence of a universally recognized definition of unilateral coercive measures and their illegal character as referred to in a number of resolutions of the Human Rights Council and the General Assembly, States prefer to present their unilateral activities as not constituting unilateral coercive measures and therefore to use other terms, including “sanctions” “restrictive measures” , and many others. Compliance companies classify sanctions as unilateral, multilateral and global. Reference is also made to international sanctions, sectoral sanctions, targeted sanctions, counter- sanctions, direct or indirect sanctions, primary or secondary sanctions, and intended or unintended sanctions. Other institutions refer to counter-terrorism cases as sanctions cases. States involved are also identified in various ways, including as sanctioning/sanctioned, targeting/targeted or sender/source States. 19. It is notable that today there is no clear definition even of the general notion of “sanctions” in international law. In the international legal doctrine, sanctions have been viewed as, inter alia, a power (possibility) to ensure the law, a punishment,17 a complex of enforcement measures applied to a delinquent State, a method to make someone comply, the negative consequence of a violation, measures to protect the international legal order, measures not involving the use of armed force to maintain or restore international peace and security, means of implementation of international responsibility,  and countermeasures or retorsions 20. The Special Rapporteur notes that many sanctions are introduced today to pursue the enhancement of democracy, human rights protection and other similar purposes, rather than to address threats to peace, breaches of peace or acts of aggression, or in response to violations of erga omnes obligations. 21. The proliferation of so-called “Magnitsky sanctions” illustrates this change. The Sergei Magnitsky Rule of Law Accountability Act of 2012 adopted by the United States imposed financial sanctions and entry bans against people and entities “determined, among other things, to be responsible for or complicit in, or to have directly or indirectly engaged in, certain human rights abuses or corrupt acts anywhere in the world”. 22. The European Union has announced the possibility of applying restrictive measures (sanctions) to achieve common goods purposes; to promote the objectives of its Common Foreign and Security Policy, including peace, democracy and respect for the rule of law, human rights and international law; and to further advance universal values for all. The United States also views sanctions as a tool to achieve foreign policy goals. The purpose of the Global Human Rights Sanctions Regulations of the United Kingdom is “to deter, and provide accountability for, … an activity which, if carried out by or on behalf of a State within the territory of that State, would amount to a serious violation by that State” of an individual’s human rights. The European Union adopted its global human rights act to “address serious human rights violations and abuses worldwide”.  23. The Special Rapporteur is mindful that the diversity of objectives of unilateral sanctions today is very different from the initial behavioural change paradigm. The academic approach identifies five types of purposes of sanctions – compliance, subversion, deterrence, international symbolism and domestic symbolism – or differentiates between denial instruments (to deny goods or benefits to targets), symbolic instruments, and punitive measures, to constrain, coerce, signal or stigmatize. The main purpose has also been identified as ensuring compliance with a command,  or changing a behaviour of the target of the sanctions by causing pain that makes the status quo too uncomfortable. 24. The Special Rapporteur notes that the traditional approach of the 1970s, that a legitimate (proper) purpose or motive can justify the use of coercion, was repeatedly used when seeking to justify the concept of humanitarian intervention in the 1990s. However, no grounds for this approach can be found in international law.” (p. 4-6)

[2] United Nations Human Rights Council. (2021). Unilateral coercive measures: notion, types and qualification (Report of the Special Rapporteur on the negative impact of unilateral coercive measures on the enjoyment of human rights, A. Douhan, A/HRC/48/59). https://undocs.org/A/HRC/48/59. “Economic, trade, financial and sectoral sanctions…Travel bans…Cybersantions…Targetd Santions…Counter-santions…Extraterritoriality…Overcompliance.” (p. 7-12)

United Nations Human Rights Council. (2021). Unilateral coercive measures: notion, types and qualification (Report of the Special Rapporteur on the negative impact of unilateral coercive measures on the enjoyment of human rights, A. Douhan, A/HRC/48/59). https://undocs.org/A/HRC/48/59. “68. The Special Rapporteur emphasizes that there are very few academic works providing a legal assessment of unilateral sanctions, and the positions of sanctioning and sanctioned States differ considerably. The Bolivarian Republic of Venezuela and the Syrian Arab Republic view unilateral sanctions as crimes against humanity.90 Cuba qualifies them as acts of aggression or the use of force in international law. The Islamic Republic of Iran considers them to be “collective punishment” “economic terrorism” , , economic “war” and genocide.91 The European Union and the United States, by contrast, view sanctions as a means of foreign policy and a way to reinforce Security Council measures.92 Other States insist that Security Council authorization can be the only grounds for unilateral sanctions. 69. The criteria for legality of unilateral sanctions are not defined either. Some publicists insist on the possibility of implementing temporary, adequate and targeted restrictive measures to guarantee security on the basis of transparent legal acts, justified by solid evidence. 93 Some base the legality of unilateral action in the existence of resolutions of the Security Council, the content of international treaty norms, rules of customary norms of international responsibility, and the humanitarian consequences of unilateral measures.94 70. The Special Rapporteur stresses that not every unfriendly act or means of applying pressure by a State can be qualified as an illegal unilateral coercive measure. 71. Articles 24 and 25 and Chapter VII of the Charter of the United Nations provide for unique powers of the Security Council to impose enforcement measures for the maintenance of international peace and security. It is also generally agreed that international organizations may impose sanctions on member States in accordance with their constituent documents” (p. 13)

[3] United Nations Human Rights Council. (2021). Unilateral coercive measures: notion, types and qualification (Report of the Special Rapporteur on the negative impact of unilateral coercive measures on the enjoyment of human rights, A. Douhan, A/HRC/48/59). https://undocs.org/A/HRC/48/59. “74. The Special Rapporteur recalls that in accordance with the draft articles on responsibility of States for internationally wrongful acts, countermeasures may only be taken by the directly affected States in response to a violation of an international obligation in order to restore fulfilment of that obligation; the measures must be temporary and proportionate to the violation, and must not violate human rights, peremptory norms of international law or humanitarian law.99 75. In accordance with article 51 of the draft articles on responsibility of States and article 54 of the draft articles on the responsibility of international organizations, countermeasures “must be commensurate with the injury suffered, taking into account the gravity of the internationally wrongful act and the rights in question” 100 . 76. The Special Rapporteur calls upon all States to engage in bona fide behaviour and interpretation when it comes to observance of international obligations. This includes refraining from interpreting the “security exception” allowed under article XXI (b) (iii) of the General Agreement on Tariffs and Trade as a justification for applying economic sanctions that would otherwise be illegal under that Agreement. 77. The Special Rapporteur also emphasizes that the repeated declaration of states of emergency by the United States to justify the introduction of unilateral sanctions does not legalize their use, especially as they do not correspond to the criteria of article 4 of the International Covenant on Civil and Political Rights. 101 78. The Special Rapporteur emphasizes the obligation of States to observe human rights treaties while deciding on retorsion measures, and the prohibition of the violation of fundamental human rights while taking countermeasures.” (p. 14)

[4] BORNA News Agency. (2026, July 22). De Zayas: US sanctions violate UN Charter, Iran justified to withdraw from NPT [Interview]. Tehran, Iran. “In an interview, De Zayas expressed serious doubt that the activation of the snapback mechanism by Western countries would achieve its desired effect. He stressed that "Economic sanctions kill," citing a Lancet study that estimates half a million extra deaths worldwide due to lack of medicine and nutrition in targeted countries. De Zayas argued that this constitutes a "hijacking of the United Nations by hegemonial powers" and that the Security Council acts ultra-vires (beyond its legal authority) when sanctions cause gross human rights violations and impede development, thereby contradicting the UN Charter's call for peace and the sovereign equality of states. He highlighted that the sanctions imposed by the U.S., France, and the UK are an attempt to impose an "anachronistic unipolar, neo-colonial order." He recalled the abuse of UN sanctions against Iraq, which was condemned as a "form of genocide."”

[5] de Zayas, A.-M. (n.d.). Economic sanctions kill. Counterpunch. “Bearing in mind that the United Nations Charter is akin to a world constitution, we should endeavour to ensure that international action is based on multilateralism and that make domestic law and practice conform with that constitution. History shows that international peace and the welfare of nations are threatened by unilateralism, including by the imposition of unilateral coercive measures against other countries, most frequently against geopolitical or geoeconomics rivals. Only UN sanctions imposed pursuant to Chapter VII of the UN Charter are legal. Unilateral sanctions contravene the letter and spirit of the UN Charter. While arms embargoes are necessary and legitimate, because they aim to deescalate conflicts and give a chance to peace negotiations, economic sanctions aimed at ‘regime change’ constitute a threat to the peace and stability of the world and should be condemned by the Security Council under article 39 of the Charter. Any country or group of countries can impose embargoes on the import and export of weapons by countries already at war or in danger of entering internal or external turmoil, but they should not gang-up on a geopolitical rival by imposing crippling economic sanctions and financial blockades that invariable impact the most vulnerable.”

[6] de Zayas, A.-M. (n.d.). Economic sanctions kill. Counterpunch. “Experience shows that economic sanctions adversely impact the enjoyment of fundamental human rights by targeted populations. Many sanctions, even ‘legal’ sanctions imposed by the United Nations Security Council (eg against Iraq 1991-2003), can cause death, even massive death, as documented by UNICEF and other international organizations (it is estimated that at least 500,000 children died because of the sanctions[1], in Venezuela some 40,000 people died because of sanctions in 2018 alone[2]). When sanctions cause such havoc, they must be lifted and other methods must be tried that are consistent with the principles and purposes of the UN. Such sanctions also contravene international humanitarian law, which specifically condemns ‘collective punishment’. Moreover, sanctions regimes that disrupt or even asphyxiate the economies of the targeted countries result in unemployment, hunger, disease, despair, emigration, suicide. To the extent that such sanctions are ‘indiscriminate’, they are tantamount to a form of state ‘terrorism’, which by definition entails indiscriminate killing, just as land mines, cluster bombs and the use of cancer-producing depleted uranium weapons. It is a disgrace for the international community that the US has disregarded 29 General Assembly resolutions demanding that the US embargo against Cuba. It is a disgrace that notwithstanding General Assembly Resolution 76/161 of December 2021 and Human Rights Council Resolution 46/5 of March 2021 – unequivocally condemning unilateral coercive measures and demanding their abolition – the United States, Canada, UK, European Union have actually intensified economic sanctions affecting the rights of hundreds of millions of human beings the world over. To pretend that these sanctions have anything to do with promoting human rights is a contradictio in adjecto, an Orwellian cognitive dissonance.”

[7] de Zayas, A.-M. (n.d.). Economic sanctions kill. Counterpunch. “The history of unilateral coercive measures is one of suffering and devastation. According to the theory, such sanctions are expected to ‘persuade’ the targeted countries to change their policies. As the pundits like to predict, sanctions should lead to such public discontent that the population will arise in anger against their governments or lead to a coup d’etat. Although the purpose of the sanctions is precisely to cause chaos, a national emergency, a volatile situation with unpredictable consequences, the political narrative that attempts to justify the sanctions invokes human rights and humanitarian principles as their true purpose. This is the classical instrumentalization of human rights for purposes of inducing ‘regime change’. But are human rights served by the sanctions? Is there any empirical evidence showing that countries subjected to sanctions have improved their human rights records? Experience shows that when a country is at war – any kind of war – it usually derogates from civil and political rights. Similarly, when a country is enduring non-conventional hybrid warfare and is subjected to economic sanctions and financial blockades, the result is not an expansion of human rights, but exactly the opposite. When sanctions trigger economic and social crises, governments routinely impose extraordinary measures and justify them because of the ‘national emergency’. Accordingly, as in classical war situations, when a country is subject to a siege, it closes ranks in an attempt to regain stability through the temporary restriction of certain civil and political rights.”

[8] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “The origins of material scarcity in Cuba date back to the so-called Special Period, triggered by the collapse of the socialist camp in the early 1990s and the tightening of the geopolitical embargo imposed by the United States, locally referred to as “the blockade” (el bloqueo). These events led to a drastic reduction of access to petrol and its derivatives, vehicles for both collective and individual use, and spare parts for maintenance and repair. As a result, in a socialist society where the great majority of motorized trips were made using collective transport, with individual vehicle ownership largely inaccessible, the State was forced to significantly reduce the supply of collective transport (Díaz-Briquets and Pérez-López 1995; Enoch et al. 2004; Piercy, Granger, and Goodier 2010; Warren et al. 2015). Three decades later, as scarcity continues affecting Cuba’s energy-hungry transport sector, we explore its causes, modalities, effects, and countermeasures in Santiago. The triple objective of the article, therefore, is to (1) unravel how scarcity influences the operations and geography of collective transport services; (2) analyze how the state institutions, workers, and passengers engage in diverse strategies to counter persistent shortages of fuel, vehicles, and spare parts; and (3) unpack how these coping mechanisms potentially generate social inequalities.” (p. 2)

[9] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “As observed by Nikolaeva and her colleagues (2019), mobility-related scarcity is often understood as a shortage of capacity to accommodate persistently high levels of movement—underpinned by material abundance, particularly that of fossil fuels. This framing frequently leads to the adoption of demand-management measures oriented towards curbing consumption (e.g. through congestion charging schemes) and pooling resources (e.g. through car-sharing and bicycle- sharing). Yet these interventions predominantly target individual behavior, encouraging consumers to make the ‘right’ mobility choices, rather than tackling the structural conditions that produce unsustainable consumption patterns (Reigner and Brenac 2019; Kębłowski, Dobruszkes, and Boussauw 2022). Moreover, mobility scarcity is often addressed through the rollout of “austere mobilities”, which “pare back state services rather than increase interventions to encourage sustainable mobility futures” (Nikolaeva et al. 2019, 351). Austere mobilities hinge on privatization, wherein collective transport is opened up to private operators, thereby eroding its potentially public character and reinforcing the logic of profit within the sector. In many cities worldwide—not only in the Global East and South (Kębłowski and Rekhviashvili 2022)—this logic has opened collective transport to a wide array of services that bear very different characteristics, notably with regard to vehicle ownership, economic models, and regulatory frameworks.” (p. 4)

[10] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “The origins of ongoing material scarcity in contemporary Cuba can be traced back to the early 1990s. The collapse of the Soviet Union in 1991 and the repeated tightening of the geo-economic embargo by the United States deprived Cuba of its main trading partners and deepened its isolation from the global economy. The impact of these changes was dramatic: from 1992 to 1994, the country’s economy shrunk by 38%, while oil imports fell by 90% (Kapcia 2021, 124). In response, Fidel Castro announced on 1st August 1990 an emergency austerity program named “Special Period in the Time of Peace”, which involved severe rationing of energy consumption. Transport was one of the most affected economic sectors, as sustained oil shortages meant “seriously reducing the provision of buses, trains and goods lorries, affecting travel to and from work” (ibid.). Consequently, the supply of collective transport in Cuban cities, which at the time was operated solely by the State, declined sharply, as did its overall frequency and reliability. For instance, in Havana, by 1993 the number of public buses in operation fell from 2,200 to 500, and consequently by 1995 the average annual kilometers travelled on collective transport amounted to just 744 km, compared to 3,000 km in 1986 (Enoch et al. 2004). In parallel, the oil shortage led to near-total disappearance of individual motorized mobility, further intensifying pressure on mobility services (Piercy, Granger, and Goodier 2010).” (p. 5)

[11] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “Piercy, Granger, and Goodier (2010) found the Cuban response to energy scarcity to be “exemplary”, arguing that “[w]hat has been done in Cuba is impressive not only in terms of bold and imaginative rescaling and reorganizing of society and the economy, but also in the scale and systemic approach adopted” (p. 170). In sum, this literature acknowledges diverse strategies developed by the Cuban society to mitigate material scarcity, including in the particularly energy-hungry sector of transport. However, while much is known about how these strategies functioned during and in the immediate aftermath of the Special Period—originally geared toward protecting Cuba’s revolutionary project of social redistribution— little is known about how they are governed and practiced today. Addressing this gap is important for several reasons. In spite of broad reconfiguration and recovery of the economy after the Special Period (Pérez Villanueva 2008), notably due to the orientation towards tourism (Galbraith, Spagnolo, and Munevar 2008), scarcity has continued affecting Cuban cities more than three decades since the initial economic downturn of the 1990s. Moreover, recent years have seen the emergence of new and particularly dire challenges, which include a series of new measures taken by Donald Trump’s first administration between 2017 and 2021 to harden el bloqueo, rampant inflation triggered by the merging of two local currencies, measures against the COVID-19 pandemic that suspended revenues from tourism, as well as recurring oil shortages related to the economic and political crisis in Venezuela, Cuba’s primary oil supplier. Finally, scholars have observed that the Cuban State has begun introducing policies oriented toward developing a more market-oriented society and economy (Kapcia 2021), which is likely to increase individual levels of resource consumption.” (p. 6)

[12] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “To understand how mobility in Santiago de Cuba is affected by material scarcity, we explore in detail how its different layers condition the local system of collective transport, influencing its operations and geography. Next, we analyze the many strategies developed to counter scarcity, which hinged on collectivization and privatization of resources. Finally, we examine how these strategies generate social inequalities, notably with regard to mobility pricing.” (p. 8)

[13] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “The socialist Cuban State remains a very strong actor in the production and governance of mobility, distinguishing it strongly from most countries in the Global South, and the Caribbean in particular, with significant implications for mobility governance under conditions of material scarcity.” (p. 8)

[14] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “With individual motorized transport restricted and rare, the vast majority of Santiago’s inhabitants —regardless of their age, gender, race, and income—use collective transport or walk, which together account for most daily trips. Cycling, although widely promoted during the Special Period, plays only a marginal role in the city’s current mobility landscape. Access to bicycles and spare bicycle parts remains extremely limited due to their status as imported and therefore costly commodities.” (p. 9)

[15] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “Nonetheless, collectivization and informalization of urban mobility entail inherent contradictions, tensions, and costs. First, to sustain mobility under conditions of scarcity, and to effectively maintain social order, the State relies on collective engagement of what we termed ‘passengers- as-workers’. However, the burden of this system is not distributed equally across the population, affecting vulnerable groups and passengers with special needs, notably those related to care responsibilities. Second, the informalization of mobility has resulted in a fragmented, unpredictable, and highly heterogenous mobility landscape, with transport options offered at widely varying prices and degrees of reliability. Third, responsibilities for mobility operations in Santiago are distributed across a range of transport actors, including both public and private operators as well as passengers themselves, negotiated through everyday interactions between State institutions, State-employed and ‘self-employed’ transport workers, and passengers-as- workers. Despite this routine co-production of transport services, there is little indication that these practices translate into social movements oriented toward mobility commoning (Enright 2020), or increased participation in institutionalized decision-making or governance processes. While these tensions and contradictions indicate that Santiago's transport system is far from ideal, improving its overall condition would require relatively modest investments: securing stable access to fuel, enabling local institutions to purchase spare parts for vehicle maintenance, and acquiring a handful of new or second-hand buses.” (p. 9)

[16] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “The persistence and pervasiveness of material scarcity affects operators and passengers across Santiago’s transport system, with structural challenges observed across the sector and affecting daily mobility. Although scarcity has evolved since the Special Period, at its core it continues to be characterized by extremely low availability of vehicles for both collective and individual use, spare parts needed for their maintenance and repair, and fuel required for their operation. Due to the geopolitical embargo imposed against the Cuban State, its limited financial resources and due payments for bus purchases—notably from China—local institutions such as the EMT cannot afford to buy new vehicles. At best, they rely on foreign donations of second-hand buses; however, none have been received in Santiago in the past decade. Consequently, the number of buses operated by the EMT during our fieldwork represented only a small fraction of its pre- Special Period fleet. Compounding this constraint, many vehicles remain out of service due to the shortage of spare parts, which cannot be bought on the global market. This challenge is further complicated by the heterogenous composition of the EMT’s fleet, which incorporates several types of Chinese-manufactured Yutong buses alongside domestically produced models—Diana buses based on chassis provided by Russian group GAZ, and Girón buses adapted from Hungary’s socialist-era Ikarus designs. Persistent fuel shortages were evident throughout our fieldwork. On a daily basis, at least one respondent complained that “there ain’t no fuel!” The EMT representatives lamented the near- impossibility of operating the bus network in these conditions, and street-level transport inspectors, responsible for managing the flow of collective transport, witnessed first-hand the strong reduction of transport supply. In addition, passengers waiting at bus stops frequently discussed the geopolitical and global roots of locally experienced scarcity, exchanging the latest news about delayed oil shipments from Russia and Venezuela. As the actor holding a monopoly over fuel distribution and sales, the State allocates available resources to essential public services, in principle prioritizing State-owned vehicles and providing the EMT with subsidized diesel oil. Its availability is largely unstable and unpredictable, however, which in times of extreme shortages translates to limited operation of public transport services.” (p. 11)

[17] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “As a result, public bus frequencies have declined significantly, with principales now operating at 60-120-minute intervals, compared to the 30-minute service levels maintained a decade earlier. As the service does not have sufficient capacity to meet the demand, and nearly all inhabitants rely on collective transport as they do not have a car or motorcycle, vehicles are severely overcrowded. This problem is particularly acute on public buses, whose passengers further experience very long waiting and boarding times. Cuentapropista services partly fill this gap, yet face even stricter limits on fuel access, with both the timing and amount of fuel purchased tightly controlled, and its availability highly unpredictable. As a result, most operators seek fuel through the informal black market, where smuggled or stolen fuel is generally available, albeit at very high prices. In May 2023, the informal market price for a liter of diesel oil reached 500 CUP (CiberCuba.com 2023), approximately twenty times the official rate.” (p. 12)

[18] Kębłowski, W., Maciejewska, M., Gillard, M., & Martínez Alonso, L. (2026). "There ain't no fuel!" Addressing material scarcity in urban mobility in Santiago de Cuba. Annals of the American Association of Geographers, 1–20. https://doi.org/10.1080/24694452.2026.2617557. “Moreover, Santiago’s dual strategy of collectivization and privatization of mobility holds important lessons for other geographical contexts—particularly given the urgency of decoupling well-being from fossil fuel consumption, notably in the realm of urban transport, an economic sector that remains highly energy-intensive. These insights are particularly relevant for cities in resource- abundant, capitalist societies of the Global North as well as rapidly motorizing cities of the Global East and South, both of which have witnessed a wide array of urban sustainable mobility policies that have sought to reduce reliance on carbon-intensive, individual, and motorized transport. While these initiatives have the capacity to facilitate a shift away from carbon-heavy mobility, they often respond to environmental imperatives in ways that exacerbate social and spatial inequalities (Reigner and Brenac 2019), generating social discontent and resistance. Thus, the first insight from Santiago highlights the need to reconceptualize mobility resources as inherently scarce rather than abundant—a paradigm shift that underscores the necessity of collectivizing and optimizing their use, rather than individualizing and trivializing it. Santiago’s public institutions and inhabitants employ remarkably resourceful strategies to make full use of the little available fuel, vehicles, and spare parts, demonstrating how resource-scarce societies can yield efficiency and sustainable outcomes.” (p. 19)

[19] Spiegel, S. J., & Le Billon, P. (2026). Oil blockades and the geopolitics of double standards: Energy imperialism, normalization of coercion and the hierarchy of suffering. Energy Research and Social Science, 138, 1–7. https://doi.org/10.1016/j.erss.2026.104825. “Oil blockades can present key moments for interrogating the politics of selectively asserting (il)legality and (im) morality. Some of the most blatant double standards in President Donald Trump's framings of oil blockades, in 2026, were unmissable while his administration blocked shipments of oil and other goods to Cuba in an effort to collapse the Cuban government. In an attempt to shield Americans and their supporters from the hardships the US was imposing on the Cuban people, US officials requested exceptional diesel import exemptions for their own embassy staff in Cuba. Meanwhile they blasted Iran's efforts to block oil shipments through the Strait of Hormuz as unacceptable, while the US and Israel continued to bomb Iranian cities in what is widely agreed to be an illegal war, and the blockade devasting Gaza continues. With supply disruptions serving as extensions of energy governance, and blockading oil and gas flows providing powerful tools to inflict pressure and harm, this Perspective article considers how politicians' double standards around blockades can be conceptualised as reflections of necro-political violence, with asymmetrical power to decide whose lives are more expendable than others.” (p. 1)

[20] Spiegel, S. J., & Le Billon, P. (2026). Oil blockades and the geopolitics of double standards: Energy imperialism, normalization of coercion and the hierarchy of suffering. Energy Research and Social Science, 138, 1–7. https://doi.org/10.1016/j.erss.2026.104825. “Double standards in the framing of blockades often operate through simple but powerful distinctions: coercion is framed as legitimate when exercised by allies, illegitimate when exercised by adversaries. In the case of Cuba, as Hernandez-Truyol pointed out more than sixteen years ago, those antagonistic to the Cuban revolution see ‘economic sanctions’ as a legitimate action that legally restricts the flow of goods, services and capital to try to influence the Castro government to change its ways. In this framing, the blocking of fuel and other necessities is a lawful restriction that simply signals justifiable disapproval of another country's policy. However, to those supportive of the Cuban revolution, the U.S ‘blockade’ is an illegitimate use of power to try to interfere with a sovereign state. In 1998, Heitzer wrote that the US blockade of Cuba is “a crime against humanity”. Critics of the blockade from multiple points of view indeed contend that the blockade, imposed by the US since 1961, violates international law, while the Trump administration argues that it is a laudable exercise of strangulating an already failed economy and bringing what it calls ‘democracy’ to the people of Cuba (which for Trump seems to be associated with his particular vision for future resort development).” (p. 3)

[21] Spiegel, S. J., & Le Billon, P. (2026). Oil blockades and the geopolitics of double standards: Energy imperialism, normalization of coercion and the hierarchy of suffering. Energy Research and Social Science, 138, 1–7. https://doi.org/10.1016/j.erss.2026.104825. “The tightening US sanctions on Cuba, especially through the oil embargo, has triggered widespread blackouts, crippling hospitals, water systems, and food supply chains, and pushing much of the population into acute hardship [27]. The deprivation of fuel imports for successive months led to the electricity grid collapsing on multiple occasions; with tourism, the economic backbone of the island, grinding to a halt, as flights were cancelled and hotels closed. Cuba's healthcare system, widely praised by international scholars, with life expectancy comparable to high-income Western nations, started to see rising infant mortality rates. Transportation and cooking had to rely on charcoal for fuel, and an array of social services halted. While US President Obama's easing of sanctions helped, Trump's first term reversed that, and Trump's second term blockading of oil from Venezuela and Mexico intensified the suffering.” (p. 3)

[22] Spiegel, S. J., & Le Billon, P. (2026). Oil blockades and the geopolitics of double standards: Energy imperialism, normalization of coercion and the hierarchy of suffering. Energy Research and Social Science, 138, 1–7. https://doi.org/10.1016/j.erss.2026.104825. “The standard of acceptability of an oil blockade is not the act itself – restricting access to vital energy flows – but the identity of the actor and the geopolitical alignment of those affected. This selective framing produces a hierarchy of suffering: some populations are seen as collateral to, or even future beneficiaries of strategic objectives, while others are protected and deemed integral to “global stability.”” (p. 3)

[23] Spiegel, S. J., & Le Billon, P. (2026). Oil blockades and the geopolitics of double standards: Energy imperialism, normalization of coercion and the hierarchy of suffering. Energy Research and Social Science, 138, 1–7. https://doi.org/10.1016/j.erss.2026.104825. “Dependence magnifies vulnerability in ways that make coercion more effective. Producers and transit states, meanwhile, become high- value targets because they sit at critical nodes in the circulation of energy and revenue, and their infrastructure can be contested during war or used as bargaining leverage in peace negotiations. In that sense, blockades are not external to energy politics; they are part of how energy governance is thought about, fought over, and enforced. Recent research also shows that the ‘energy weapon’ can be limited, uneven, and often reversible. States can adapt through diversification, stockpiling, rerouting, substitution, and market redesign, while sanctions may fragment trade rather than produce simple shortages. Even so, the core pattern remains: fossil fuel systems generate asymmetries of dependence that make coercion possible, while coercion in turn reshapes the structure of energy markets. The result is a durable set of linkages between war, blockades, and resource control in which energy is both the object of conflict and one of its principal instruments, especially in countries where fossil fuel export or import dependence amplifies vulnerability.” (p. 4)

[24] J. Milton, Send Canadian oil to Cuba, Canadian Centre for Policy Alternatives, 2026. https://www.policyalternatives.ca/news-research/send-canadian-oil -to-cuba/.  “The situation in Cuba is dire. The country, already pushed to a breaking point since the U.S. economic blockade escalated during Trump’s first term (continuing under Biden), is now experiencing power blackouts that last up to 16 hours per day. Fuel shortages are widespread—as are, increasingly, food shortages. Local agriculture is at risk of collapse due to the lack of fuel, which could tip the island into a famine. Hospitals are running on generators and the fuel is drying up. People are likely already dying as a result of this unprovoked escalation.”

[25] Cortright, D. (2001, December 3). A hard look at Iraq sanctions. The Nation. https://archive.globalpolicy.org/component/content/article/170-sanctions/42275.html. “The humanitarian disaster resulting from sanctions against Iraq has been frequently cited as a factor that motivated the September 11 terrorist attacks. Osama bin Laden himself mentioned the Iraq sanctions in a recent tirade against the United States. Critics of US policy in Iraq claim that sanctions have killed more than a million people, many of them children. Saddam Hussein puts the death toll at one and a half million. The actual numbers are lower than that, although still horrifying.”

[26] Cortright, D. (2001, December 3). A hard look at Iraq sanctions. The Nation. https://archive.globalpolicy.org/component/content/article/170-sanctions/42275.html. “The grim question of how many people have died in Iraq has sparked heated debate over the years. The controversy dates from 1995, when researchers with a Food and Agricultural Organization (FAO) study in Iraq wrote to The Lancet, the journal of the British Medical Society, asserting that sanctions were responsible for the deaths of 567,000 Iraqi children. The New York Times picked up the story and declared "Iraq Sanctions Kill Children." CBS followed up with a segment on 60 Minutes that repeated the numbers and depicted sanctions as a murderous assault on children. This was the program in which UN ambassador (and later Secretary of State) Madeleine Albright, when asked about these numbers, coldly stated, "The price is worth it." Albright's comments were shocking, as were the numbers, but doubts were soon raised about their validity. A January 1996 letter to The Lancet found inconsistencies in the mortality figures. A follow-up study in 1996, using the same methodology, found much lower rates of child mortality. In October 1997 the authors of the initial letter wrote again to The Lancet, this time reporting that mortality rates in the follow-up study were "several-fold lower than the estimate for 1995--for unknown reasons." While the initial report of more than 567,000 deaths attracted major news coverage, the subsequent disavowal of those numbers passed unnoticed in the press.”

“The two most reliable scientific studies on sanctions in Iraq are the 1999 report "Morbidity and Mortality Among Iraqi Children," by Columbia University's Richard Garfield, and "Sanctions and Childhood Mortality in Iraq," a May 2000 article by Mohamed Ali and Iqbal Shah in The Lancet. Garfield, an expert on the public-health impact of sanctions, conducted a comparative analysis of the more than two dozen major studies that have analyzed malnutrition and mortality figures in Iraq during the past decade. He estimated the most likely number of excess deaths among children under five years of age from 1990 through March 1998 to be 227,000. Garfield's analysis showed child mortality rates double those of the previous decade.”

[27] Cortright, D. (2001, December 3). A hard look at Iraq sanctions. The Nation. https://archive.globalpolicy.org/component/content/article/170-sanctions/42275.html. “Garfield has recently recalculated his numbers, based on the additional findings of the Ali and Shah study, to arrive at an estimate of approximately 350,000 through 2000. Most of these deaths are associated with sanctions, according to Garfield, but some are also attributable to destruction caused by the Gulf War air campaign, which dropped 90,000 tons of bombs in forty- three days, a far more intensive attack than the current strikes against Afghanistan. The bombing devastated Iraq's civilian infrastructure, destroying eighteen of twenty electricity-generating plants and disabling vital water-pumping and sanitation systems. Untreated sewage flowed into rivers used for drinking water, resulting in a rapid spread of infectious disease. Comprehensive trade sanctions compounded the effects of the war, making it difficult to rebuild, and adding new horrors of hunger and malnutrition. Sanctions opponents place the blame for Iraq's increased deaths squarely on the United States and the continuing UN sanctions. Certainly the United States bears primary responsibility for the war and unrelenting sanctions. Washington has pursued a punitive policy that has victimized the people of Iraq in the name of isolating Saddam Hussein. The United States has continued to bomb Iraq over the years, and if some in Washington get their way, it will soon launch new military attacks in the name of antiterrorism.”

[28] Cortright, D. (2001, December 3). A hard look at Iraq sanctions. The Nation. https://archive.globalpolicy.org/component/content/article/170-sanctions/42275.html. “The Security Council has steadily expanded the oil-for-food program. In 1998 it raised the limits on permitted oil sales, and in 1999 it removed the ceiling altogether. Production has risen to approximately 2.6 million barrels per day, levels approaching those before the Gulf War. Oil revenues during the last six months of 2000 reached nearly $10 billion. This is hardly what one would call an oil embargo. Oil exports are regulated, not prohibited. Funds are still controlled through the UN escrow account, with a nearly 30 percent deduction for war reparations and UN costs, but Baghdad has more than sufficient money to address continuing humanitarian needs. Said Secretary General Kofi Annan in his latest report, "With the improved funding level for the programme, the Government of Iraq is indeed in a position to address the nutritional and health concerns of the Iraqi people."”

[29] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “In the south/centre, infant and under-5 mortality increased during the 10 years before the survey, which roughly corresponds to the period following the Gulf conflict and the start of the United Nations sanctions. Infant mortality rose from 47 per 1000 live births during 1984–89 to 108 per 1000 in 1994–99, and under-5 mortality rose from 56 to 131 per 1000 live births. In the autonomous region during the same period, infant mortality declined from 64 to 59 per 1000 and under-5 mortality fell from 80 to 72 per 1000. Childhood mortality was higher among children born in rural areas, children born to women with no education, and in boys, and these differentials were broadly similar in the two regions.” (p. 1851)

[30] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “During the past 20 years Iraq has witnessed spectacular social and economic development, followed by a dramatic decline. The per capita gross domestic product (GDP), for example, was estimated at US$3510 in 1989, but only US$450 in 1996.1 This was primarily due to an 85% reduction in oil production and the devastation of industrial and service sectors of the economy.” (p. 1851)

[31] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “Before 1991, much progress has been made in building roads and infrastructure as well as improving human skills by expansion of education and advanced training. During the same period, healthcare reached about 97% of the urban and 79% of rural population.3 The healthcare system was based on an extensive and expanding network of health facilities linked up by reliable modes of transport and communications. The country had a well-developed water and sanitation system and 90% of the population was estimated to have access to safe drinking water.4 Infant mortality fell from 71 per 1000 live births in 1965 to 29 per 1000 in 1989 while under-5 mortality declined from 111 to 44 per 1000 live births.5,6 These gains were stopped with the start of the Gulf conflict. Trade sanctions were imposed against Iraq in August, 1990. The war started on Jan 16, 1991, and a ceasefire was declared after 6 weeks. After the Gulf War, the autonomous region of Iraq, inhabited mainly by Kurds, was placed under United Nations administration and sanctions were strictly enforced against Iraq.” (p. 1851)

[32] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “Recent malnutrition surveys in Iraq have, however, shown that the prevalence of underweight under-5 children has increased two-fold since 1991—ie, from 12% to 23%.9 Since an increase in malnutrition is usually associated with increased childhood mortality, it is likely that mortality has also increased.” (p. 1851)

[33] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “The infant mortality rate (IMR) and the under-5 mortality rate were estimated for 5-year periods before the survey (figure 2). In the south-centre, both IMR and under-5 mortality rate consistently show a major increase in mortality over the 10 years preceding the survey (which roughly corresponds to the period following the Gulf conflict). The IMR more than doubled from 47 (95% CI 44–50) for the period roughly equal to 1984–89 to 108 (104–112) deaths per 1000 live births for the period roughly equal to 1994–99. Note that by 1984–89, the IMR in the south/centre had declined from 57 (52–62) deaths per 1000 live births during the period roughly corresponding to 1974–79. The IMR was, however, never as high in the previous years as in the 5 years just before the survey. Under-5 mortality rate also increased during the same time from 56 (52–58) to 131 (127–135) deaths per 1000 livebirths. In a short span of 10 years following the Gulf conflict, childhood mortality in the south/centre thus increased more than two-fold and to levels above those of 20–24 years previously.” (p. 1854)

[34] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “Since 1991, most of the hospitals and health centres in the south/centre of Iraq have had little or no repair or maintenance work carried out. The functional capacity of the healthcare system has been further degraded by shortages of water and power supply. Communicable diseases, such as water-borne diseases and malaria, which had previously been under control, returned as epidemics in 1993 and have now become part of the endemic pattern of the precarious health situations in the south/centre of Iraq. ” (p. 1856)

[35] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “Acute malnutrition in the south/centre region of Iraq rose from 3% to 11% and the percentage of low-birth- weight babies (less than 2·5 kg) rose from 4% in 1994 to about 25% of registered births in 1997, mainly due to maternal malnutrition which was estimated to be up to 70% in 1997.20 The most vulnerable groups have been the hardest hit, especially children under 5 years of age who are being exposed to unhygienic conditions.18 Drinking water is currently accessible only to 50% of urban and 33% of rural populations in south/centre, which is far below the proportion before sanctions (90% in urban and 70% in rural areas21) In April, 1995, the UN Security Council adopted a resolution (SCR 986), which was intended to provide for the humanitarian needs of the Iraqi people. This initiative came to be known as the “Oil-for-Food” programme. The adoption of the “Oil-for-Food” programme has played an important part in averting major food shortages in Iraq and has helped to alleviate the health situation, especially in the autonomous region. Since the beginning of the programme, the extent of malnutrition seems to have stabilised in the more populous south/centre of Iraq, albeit at an insufficient caloric level, whereas in the autonomous governorates the situation has improved somewhat. In the autonomous governorates the availability of equipment and trained staff, as well as drugs and supplies, have contributed to substantially increased patient attendance and better care. There is a decline in some infectious diseases such as measles, and better control of poliomyelitis. Water and sanitation have also improved in the autonomous region, because of the “Oil-for-Food” programme.” (p. 1856)

[36] Ali, M. M., & Shah, I. H. (2000). Sanctions and childhood mortality in Iraq. The Lancet, 355(9218), 1851–1857. https://doi.org/10.1016/S0140-6736(00)02289-3. “Results from the two surveys on childhood and maternal mortality in Iraq clearly show that childhood mortality in the south/centre increased during the period of the UN sanctions that followed the Gulf conflict. Information from several other studies and surveys shows an increase in the rates of malnutrition and in babies born with low birthweight. In the 10 years since the Gulf conflict, infant and under-5 mortality has more than doubled in the south/centre. Childhood mortality rates in the south/centre are now much higher than those 20–24 years ago.” (p. 1856)

[37] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “Over the ensuing twelve years, these sanctions – referred to in Iraq as al-hisar (the siege) – unleashed a relentless unraveling of the nation’s social and economic fabric. Decades of progress in public health and education were rapidly reversed as the sanctions regime rendered Iraq isolated, impoverished, and rife with corruption. The widespread scourge of disease, environmental degradation, and pervasive suffering foretold the nation’s descent into a pro- tracted humanitarian crisis. Among the most devastated casualties was Iraq’s once admired healthcare system, which crumbled under the dual pressure of infrastructural collapse and the mass exodus of its medical professionals.” (p. 71)

[38] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “Bereft of vital supplies and faced with a surge in infections, Iraqi physicians were compelled to improvise, devising unorthodox methods in wound care and antibiotic use. While born out of necessity, these adaptations sowed the seeds of chronic and resistant infections, a crisis that continues to haunt Iraq’s beleaguered healthcare system. These medical challenges transcended Iraq’s borders, reshaping regional healthcare dynamics and aggravating a broader public health crisis.” (p. 71-72)

[39] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “In recent decades, economic sanctions have often been portrayed as a gentler alternative to the overt violence of war, a diplomatic tool designed to exert pressure without resorting to military intervention. Framed within the paradigm of “global governance,” sanctions aim to enforce compliance from states, individuals, or entities by economically isolating them. The underlying assumption is that such measures will compel political actors to align with international norms through the coercive power of economic deprivation. Yet, a growing body of interdisciplinary scholarship has interrogated the paradoxes and profound consequences of sanctions, challenging the notion that they are a “humane” alternative to warfare. While ostensibly directed at influencing state behavior on the international stage, sanctions frequently weaken a government’s capacity to shield its citizens from their fallout. The resulting economic and social upheaval disproportionately impacts the most vulnerable, disrupting livelihoods, undermining survival strategies, and corroding the social and political fabric of affected nations.” (p. 72)

[40] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “By the 1970s and 1980s, Iraq had emerged as a regional leader in health- care.28 The system, modeled on the UK’s National Health Service (NHS), pro- vided free public-sector medical education and care. Medical students followed a rigorous six-year curriculum of studies based on UK standards, which were supplemented by residencies in public hospitals, mandatory rural service, and military postings as a form of reciprocity for state-funded education. This commitment extended to postgraduate training abroad, particularly in British and American institutions, ensuring that Iraqi doctors were equipped with the highest international standards of medical knowledge. During this period, Iraq’s healthcare indicators showed remarkable progress. Under the Ba’athist rule, the expansion of socialist policies fostered significant improvements in maternal and infant mortality rates, access to healthcare, and nutrition standards.29 The estimated per capita daily caloric availability rose from 1,958 in 1961 to 3,400 in the period from 1984 to 1990.30 Even amid the gruel- ing Iran–Iraq War (1980–1988), the healthcare system adapted and thrived, with investments in hospitals, medical schools, and primary healthcare.31 Women’s organizations played an essential role in public health initiatives, driving vaccina- tion campaigns, improving health literacy, and reducing mortality rates.32 By the 1990s, Iraq’s healthcare system had grown into a comprehensive network of 131 hospitals and 851 health centers, serving nearly 90 percent of the population.33 However, the Gulf War and subsequent sanctions shattered this system.” (p. 77)

[41] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “The sanctions period devastated Iraq’s healthcare workforce. Beginning in the 1990s, Iraq experienced a persistent exodus of doctors and nurses, a trend that accelerated after the 2003 US invasion. Medical professionals cited deteriorating training conditions, financial hardship, and the unsafe work environ- ment as key factors driving their departure. Compounding this brain drain, the intellectual embargo imposed by sanctions restricted access to updated medical literature, journals, and textbooks, leaving Iraq’s medical education system increasingly isolated from global advancements. Nursing, a profession long underdeveloped in Iraq, faced a further breakdown under the sanctions. The healthcare system, historically reliant on foreign nurses, was left with a diminished workforce as many expatriates returned home. Local nurses, facing paltry wages and grim working conditions, abandoned their roles in favor of better-paying opportunities outside the healthcare sector. By the immediate aftermath of Operation Desert Storm, Iraq’s largest medical complex, Medical City, functioned with less than half of its nursing staff. Healthcare workers bore the dual burden of enduring the economic collapse, while struggling to care for the vulnerable population under extreme resource constraints. Hyperinflation and the devaluation of the Iraqi dinar reduced healthcare workers’ monthly salaries to an equivalent of $3–$10. This forced many to seek second jobs, compromising their ability to serve the health system effectively. By 2003, Iraq’s healthcare workforce had been decimated. The country had 53 physicians and 46 nurses per 100,000 people, figures that paled in compar- ison to neighboring countries.” (p. 78)

[42] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “As the sanctions deepened, conditions in Iraqi hospitals rapidly deteriorated. The economic stranglehold system imposed by the UNSC disrupted the importation of critical medical supplies, undermined preventive and curative services, decimated the infrastructure for controlling infectious diseases, and hampered local drug production. Chronic shortages of medication left patients with long-term illnesses in constant distress, while surgical procedures became increasingly hazardous due to the lack of essential equipment and sterile environments. Despite the escalating need for medical supplies, the Iraq Sanctions Committee systematically put “holds” on medical goods purchased through the OFFP, delaying the import of these goods. The holds on critical goods, particularly those related to the infrastructure, increased throughout the decade. By the early 2000s, the volume of medical items placed on hold had tripled, from $150 million in 2000 to $450 million in 2002. These included air compressors, insecticides, spare medical parts for sterilizers and autoclaves, oxygen concentrators, electrical generators and cables, sprayers, freezers, and accessories for oxygen production plants. Even laboratory materials, medicines, and dental laboratory equipment were not spared, exacerbating an already critical situation in Iraq’s healthcare system. The inability to procure such items left hospitals ill-equipped to provide even rudimentary care.” (p. 79-80)

[43] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “The dire situation extended to hospitals maintenance budget, which had been slashed to unsustainable levels. At one 200-bed hospital, the monthly cleaning budget was reduced to a mere IQD1,500 (approximately $2), sufficient only to purchase hand soap for operating theatres. Without access to disinfectants or antiseptics, cleaning staff were limited to using just water for sanitation. Compounding the issue, staffing levels plummeted; for instance, the number of cleaning staff at this hospital fell from twenty to just two. Essential medical supplies were similarly scarce. Hospitals reported frequent shortages of intravenous fluids, cannula tubes, urine catheters, sterile gloves, and surgical stitches – items fundamental to routine medical and surgical procedures. The unavailability of anesthetics and surgical material forced hospitals to cut daily elective surgeries drastically. In Mosul, for example, the number of such procedures fell from fifteen to two. Surgeons were compelled to economize, reusing sutures and rationing painkillers like pethidine, an opioid, which became so scarce that ampules had to be distributed among patients.54 The breakdown of sterilizers and autoclaves, coupled with delays in obtaining replacement parts due to sanctions, further jeopardized patient safety and postoperative outcomes.55 Patients bore the brunt of these deficiencies. Many were required to bring their own blankets and heating units during the frigid winter months and to endure sweltering conditions in summer due to nonfunctioning cooling system. Laboratory services also suffered a significant decline, with investigations dropping by 54 percent, during the first four years of the sanctions, and a further 14 percent by 1997.58 A WHO estimated that by the same year, only 25 percent of the medical equipment in Iraq’s healthcare facilities remained operational, crippled by restrictions on imports and lack of financial resources. Broken refrigeration systems in vaccination centers hindered the preservation of vaccines, undermining immunization programs and leaving vulnerable populations exposed to preventable diseases.” (p. 80-81)

[44] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “Operating under these suboptimal conditions, doctors were forced to impro- vise and economize, often at the expense of patient safety. At a Baghdad teaching hospital, the theatre manager was permitted to issue only three pairs of surgical gloves per operation. In some cases, the same suction tube was used for multiple patients. Orthopedic surgeons were compelled to delay procedures, with one case requiring a patient to wait until a plate and screws could be removed from another patient during surgery. As I have recounted elsewhere, “Doctors reused cannulas to economize, replaced Foley catheters with nasogastric tubes to empty bladders, and sterilized disposable gloves and remains of surgical sutures to be used on the next patient.”” (p. 82-83)

[45] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “By 1997, hospitals reported decisions as they battled infections with inadequate tools, knowing that even their best efforts might not suffice. Writing about their experience this period, Muhammed Akunjee and Asif Ali explain described the fatal impact of limited medical options: Common bacterial and fungal infections, usually easily controllable with appropriate antibiotic and antifungal agents, have become fatal conditions. Patients presenting with infection are empirically treated with gentamicin and ampicillin at the onset of symp- toms, since no alternative antibiotics are available. If there is no response, the infection spreads and the patient more often than not dies. The only antifungal available is ketoconazole, but this is rarely used due to problems of hepatic toxicity. More efficacious medication such as amphotericin B and fluconazole are simply unavailable. It is feared that the overuse of certain medications will lead to antibiotic resistance in the long- term. It seems only a matter of time before infectious epidemics become widespread in Iraq with the lack of appropriate treatment available. infection rates for clean wounds rising from 5 percent to an alarming 25–30 percent. These heightened risks forced doctors to adopt preventative measures, often involving the indiscriminate use of broad-spectrum antibiotics. Regardless of the procedure, patients were prescribed multiple antibiotics to combat potential bacterial and fungal infections. Yet the unpredictable supply of antibiotics frequently interrupted treatments, leading to suboptimal dosing, reliance on expired drugs, or abrupt changes in medication based on what was available. As hospitals struggled to secure consistent supplies, many patients and their families turned to the black market, which became flooded with counterfeit and expired drugs. Others relied on relatives abroad to send life-saving medications, highlighting the frac- tured state of Iraq’s pharmaceutical system. Even within hospitals, doctors had to contend with limited resources. Instead of basing prescriptions on laboratory-confirmed diagnoses, they relied on clinical judgment, as laboratories lacked the reagents and equipment needed to conduct sensitivity testing. These conditions created a breeding ground for antibiotic resistance, where partial courses of treat- ment or ineffective drugs allowed infections to persist and evolve. The consequences of these practices were devastating. Patients who survived surgery often succumbed to chronic, resistant infections, with septicemia becoming an increasingly common cause of death. Doctors faced heartbreaking decisions as they battled infections with inadequate tools, knowing that even their best efforts might not suffice. Writing about their experience this period, Muhammed Akunjee and Asif Ali explain described the fatal impact of limited medical options: Common bacterial and fungal infections, usually easily controllable with appropriate antibiotic and antifungal agents, have become fatal conditions. Patients presenting with infection are empirically treated with gentamicin and ampicillin at the onset of symp- toms, since no alternative antibiotics are available. If there is no response, the infection spreads and the patient more often than not dies. The only antifungal available is keto- conazole, but this is rarely used due to problems of hepatic toxicity. More efficacious medication such as amphotericin B and fluconazole are simply unavailable. It is feared that the overuse of certain medications will lead to antibiotic resistance in the long- term. It seems only a matter of time before infectious epidemics become widespread in Iraq with the lack of appropriate treatment available.” (p. 83-84)

[46] Dewachi, O. (2025). Sanctions and their lasting legacy on Iraq's healthcare. In J. Gordon (Ed.), Economic sanctions from Havana to Baghdad: Legitimacy, accountability, and humanitarian consequences (pp. 71–91). Cambridge University Press. “In conclusion, the repercussions of the sanctions imposed on Iraq extend far beyond the immediate dismantling of its healthcare system. They have created a lasting legacy of biosocial vulnerability, embedding structural weak- nesses that continue to destabilize public health in Iraq and the region. The rise of AMR in Iraq is emblematic of these enduring impacts, highlighting the need for a multidisciplinary approach to understanding and addressing the aftereffects of sanctions and war. The long shadow of sanctions under- scores a fundamental truth: Even when framed as nonviolent tools of diplo- macy, their effects can rival the devastation of war, leaving wounds that endure for generations.” (p. 87)

[47] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “Far from ending the war after the defeat of its South Vietnamese client regime, the United States continued to wage economic, political, and cultural war on Vietnam long after 1975. In this book, I examine this post-1975 phase of U.S. relations with Vietnam, which I call the “American war on Vietnam” (1975-2000). In particular, I examine the ways in which cultural representations intersected and interacted with the formation of foreign policy during this period. Both of these activities, I argue, were driven by the same cultural logic of “normalizing” the historical memory of the war, reinserting recuperative American narratives at the center of public discourses about the war while marginalizing and silencing Vietnamese and other alternative and oppositional voices. By rendering Vietnamese subjects silent or invisible in American films, television shows, and comic books about the war, while ignoring the real impact of U.S. policies on Vietnam, the different “fronts” of the American war on Vietnam combined to reconstruct the cultural, political, and economic work of American em- pire in the wake of a long, devastating, and divisive war. The American war on Vietnam was thus as much a battle for the cultural memory of the war in American society as it was a lengthy and bitter economic, political, and diplomatic war against the nation and people of Vietnam.” (p. 2)

[48] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “In short, the United States was both indirectly and directly responsible for defining the broad terms under which the Vietnamese would recon- struct and rebuild their nation. Michel Foucault's phrase for such manifestations of power is “structuring the possible field of action.” ' In this same sense I will show, for instance, that although the brutal American embargo did not determine the fate of a Socialist Vietnam, it did limit the range of possibilities available to the state and its people, by restricting the amount of aid and capital flowing into the country and the amount and type of exports flowing out of it, and by blocking for several years after 1975 Vietnamese applications for membership in the United Nations.” (p. 6)

[49] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “From economic embargoes to denials of humanitarian aid, from ignoring the ongoing environmental devastation caused by the United States during the military phase of the war to actively funding and arming the forces fighting Vietnam, many aspects of U.S. policy toward Vietnam after 1975 are difficult to distinguish from similar “wartime” activities. The fact that, after 1975, these activities are supported by a cultural front strengthens this interpretation. Without a simply articulated definition of what does and does not constitute war, then, I leave it to readers to decide for themselves whether or not U.S. policy toward Vietnam both before and after 1975 should be classified as warlike.” (p. 10-11)

[50]  Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “By the time the Vietnamese were once again out of sight and out of mind in mid-May of 1975, the new war against Vietnam already had begun. As Saigon was being liberated by the revolutionary forces of Vietnam, the Ford White House swiftly imposed harsh economic sanctions on South Vietnam, to match those long in place against the North. In the midst of his meditations on April 30, the secretary of state found time to recommend to the Commerce Department that it freeze an estimated $70 million in South Vietnamese assets held by American-owned banks and their foreign subsidiaries.” (p. 13)

[51] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “Despite all the distractions of the Mayaguez incident, however, Kiss- inger found the time to authorize yet another decision that would keep Vietnam from disappearing from view for at least a little while longer. On May 14, the State Department recommended to the secretary of commerce that South Vietnam and Cambodia be placed in the most restricted category of export controls, under which American citizens were forbidden to send people in those countries any humanitarian aid. Within the year, the United States would enlarge its sanctions program, denying the Vietnamese international aid, access to international capital, and membership in the United Nations. Far from being “unable to affect the ongoing tragedy,” as Kissinger put it, the United States began a new campaign against Vietnam before the guns of the old one had even gone silent. Far from receding into isolation, the United States after 1975 remained in a position to shape the direction and contour of events in Vietnam and in Southeast Asia as a whole. The war on Vietnam continued; only the weaponry had changed. The course of action set in motion on May 14 by Kissinger’s authorization of the embargo was not examined at the time for its long-term policy implications and was never intended to be permanent, but it would never- theless define and limit the range and scope of future interactions between Vietnam and the United States. Decades earlier, the United States had first supported a French war in Indochina and later gone to war there itself, continuing politics “by other means.” In the spring of 1975, the United States began a new phase of the battle for Vietnam and Southeast Asia, continuing war by other means.” (p. 14)

[52] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “The amendments also prompted a sharp response from the World Bank itself, leading to one of the supreme ironies of the ongoing American War against Vietnam. Robert McNamara, who had taken over as president of the World Bank in 1967 after leaving the Johnson administration, came, in effect, to Vietnam’s defense a decade later, admonishing Congress not to place any restrictions on American contributions to the World Bank. McNamara’s letter was instrumental in eventually getting the restrictions dropped, but the foreign aid battle still ended badly for the people of Southeast Asia. Taking heat from numerous factions in the legislature, and having already committed an enormous amount of political capital on other international issues, Carter was ultimately forced to give in to the politicization of the IFIs. In September, Congress and the White House reached an agreement on the foreign aid bill, which placed no restrictions on American contributions to the IFIs, but only after the White House agreed that it would instruct its representatives at those institutions to vote against any aid to Vietnam and the other countries. As Hurst notes, “the administration thus closed off the last avenue by which it could reach an accommodation with Hanoi involving the provision of aid. All it could do now was. wait and hope that the Vietnamese would drop their demand.” 3 The Vietnamese, however, desperate for aid and still suffocating under the embargo, were in no position to drop their demand. On December 19, the two delegations again met in Paris, and Holbrooke informed Hien that he had no instructions to offer any aid, even as a private, off-the-record statement. Holbrooke later told Nayan Chanda that during a break in the sessions Hien said, “You just whisper in my ear the amount you'll offer, and that is enough.” “I said, ‘I am sorry. I have no authority to do that.’” Holbrooke also informed Hien that the United States was not willing to drop the embargo, and the talks once again ended with no substantive progress. The prospects for normalization, so strong only a few months earlier, had been greatly diminished. As Hurst describes it, the failure to advance toward normalization in 1977 should be chalked up to both Hanoi and Washington. Without question, the Vietnamese underestimated the level of aversion to Hanoi felt by many in Congress, and could have played their hand much better when confronted with such congressional animosity. Nevertheless, the ultimate responsibility for failure must be placed with the United States. The Vietnamese, despite their initial obstinacy on the matter of reparations, continually demonstrated their flexibility in seeking some form of aid that would be acceptable to the United States. In the spring of 1977, the same type of amendments restricting aid through IFIs had been defeated in Congress, and the Vietnamese had indicated their willingness to receive aid through those institutions. But, as Hurst argues, an “opportunity was missed” because of the Carter administration’s “over- confidence and unwillingness to provide Vietnam with aid.” ” (p. 37-38)

[53] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “There were several possible solutions to this infrastructure problem, all limited to some degree by the American sanctions program. Most international corporations were unwilling or unable to invest or engage in reconstruction programs by themselves, while many of the firms best suited to the size and scope of the work required were U.S. companies, still banned from the bidding process. The projects might also be funded by bilateral aid, but likely candidates such as France and Japan were still at least nominally supporting the U.S. embargo. Although both countries had formally resumed trade with Vietnam, they remained unwilling to provide the levels of direct aid necessary for large infrastructure projects. Finally, the most plausible if not the most ideal scenario for funding the projects was to secure loans from an international financial institution (IFI). Because of the American-led ban on loans to Vietnam, however, the IMF, World Bank, and Asian Development Bank were all prohibited from making such arrangements with Hanoi. While France and other nations had pushed for an end to the policy since the withdrawal of Vietnamese troops from Cambodia in 1989, the United States and Japan had lobbied to keep the ban in place. By the end of 1991, though, Japan joined France in leading the charge for a resumption of lending and restructuring of Vietnam’s existing debt—still in the face of stiff opposition from the U.S.8 The intransigence of the Bush administration on the issue of IFI lending is, at first glance, the most glaring oddity of the roadmap. Why would the administration place the resumption of international lending to Vietnam—a relatively minor step, at least politically, compared with full normalization—in the final phase of the roadmap, only after the end of the American trade embargo? Why would it actively prevent Vietnam from financing its own projects, or other nations from helping to finance those projects, through IFIs? The lingering animus of many U.S. policymakers toward Vietnam provides a partial explanation, as does the ongoing desire by Washington to use the IMF and World Bank as tools to enforce American foreign policy. The complete explanation, however, would only become publicly apparent in later congressional hearings. As was then made clear, under the terms of the current U.S. sanctions regime American firms would still be barred from bidding on or participating in any IFI-sponsored projects if lending to Vietnam resumed. The Bush administration thus designed the roadmap’s steps to prolong the politicization of the IFIs: so that American firms would not lose further business opportunities to their international counterparts, the United States would continue to obstruct IFI participation in the reconstruction of Vietnam until American companies were free to enter the market—with access, of course, to industry-favorable IFI financing terms. As a result of such policies, as well as the regularly encountered speed bumps provided by the POW/MIA community, Vietnam would have to wait several more years to reach the end of the road to normalization.” (p. 164-165)

[54] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “Business interests were clearly overtaking the POW/MIA lobby as the prime source of testimony at these hearings. In addition to the U.S.- Vietnam Trade Council, other pro-business lobbying groups were begin- ning to coalesce around the effort to end the embargo. At the July Senate hearings, Al Baker, CEO of Halliburton, testified on behalf of the National Foreign Trade Council, a coalition of over five hundred large U.S. firms engaged in trade and investment around the world. The U.S. Chamber of Commerce was also lined up in favor of lifting the embargo, submit- ting a detailed prepared statement describing the “lost opportunities” for American businesses in Vietnam. Baker pointed to the combination of Vietnam’s growing economy and the large potential market share for various industries—particularly petroleum exploration and development, one of Halliburton’s specialties—arguing that the embargo was only harming United States interests. While Baker and the NFTC supported the administration’s decision to lift the IMF restrictions, they criticized the president for not going far enough. Under the embargo, U.S. firms were still banned from bidding on or participating in the many infrastructure projects likely to result from the new IMF loans. Thus, Baker pointed out, American businesses found themselves “in the unusual position of hav- ing its own government use U.S. tax dollars directly or indirectly to fund economic activity from which they are legally barred.” Perhaps no issue sums up the central tension of American policy— access versus leverage—better than the question of U.S. opposition to loans from the IMF. During the normalization debates of the late 1970s one of the major concerns among policymakers was the “politicization” of IFIs. The Carter administration and such IFI representatives as Robert McNamara, president of the World Bank, opposed using the institutions to enforce U.S. policy in developing countries. A decade later, their concerns had been forgotten in the debate over lifting the embargo. The institutions were by 1991 clearly under the thumb of the United States—which continued to exercise its veto to ensure that there would be no loans to Vietnam from the IMF, World Bank, or Asian Development Bank. Absent any discussion of whether or not it was legitimate for the United States to use the institutions to punish the Vietnamese, the only issue by then was how long to continue the ban. Meanwhile, the standard assumption of various anti-Vietnamese constituencies, particularly the POW/MIA lobby, was that the Vietnamese not only wanted but needed the loans. The reality was far more complex. Although it was barred from direct lending to Vietnam, the IMF was active in Hanoi. Representatives of the fund were not barred by U.S. policy from advising Vietnam, and they continued to do so throughout the 1980s, peddling such neoliberal “reform” measures as privatizing state-controlled resources and programs (including health care and education), liberalization of investment codes (particularly, foreign ownership regulations), and ending subsidies for agriculture and industry. By the end of 1987, as part of its market-based doi moi economic program, Hanoi had, in the words of historian Gabriel Kolko, agreed to “the entire IMF package, one that many countries are reluctant to accept, much less implement.”” (p.189-190)

[55] Martini, E. A. (2007). Invisible enemies: The American war on Vietnam, 1975–2000. University of Massachusetts Press. “After a twenty-year impasse, on January 28, 1995, the United States and Vietnam signed a historic Agreement Concerning the Settlement of Certain Property Claims. The agreement arranged for Vietnam to pay private claims of United States nationals (“both natural and juridical persons”) in the amount of $208,510,481.3! The claims of the United States government for the RVN loans were not covered by this arrangement. Only in 1997 did the two governments reach an agreement on this issue, when Treasury Secretary Robert Rubin and Finance Minister Nguyen Sinh Hung agreed that the SRV would repay $145 million in loans from the former Saigon regime. The agreement also called for a “down payment” of $8.5 million to cover the interest on the loans. The down payment was due within 30 days; the full loan was to be paid off through “regular payments” until 2019.1” (p. 202)

[56] Wallace, C. P. (1990, April 29). 15 years after war's end, the U.S. still fights to keep Vietnam isolated: Diplomacy: Washington has linked normalization to help on MIAs and Cambodia. But support for ignoring the war-ravaged nation may be fading. Los Angeles Times. https://www.latimes.com/archives/la-xpm-1990-04-29-mn-300-story.html. “Pauperized by fighting wars since the 1940s, Vietnam needs at least $12 billion to get back on its feet, according to a recent European study of the economy. But the U.S. blockade has not only cut off American assistance, it has also kept nations such as Japan from providing help.  “The embargo is crippling the Vietnamese economy,” said Raymond Eaton, director of Export Development Trading Corp., an Australian-Thai concern based in Bangkok. “They have no hard currency, and as long as that goes on, Vietnam is going to be handicapped.”  Supporters of efforts to end the embargo are particularly critical of what they describe as a hardening of U.S. policy last year after Vietnam’s withdrawal of troops from Cambodia.  Since 1979, the United States had demanded Vietnamese withdrawal as a condition of normalization. Other conditions included progress on resolving cases of U.S. service personnel missing in action and on Amerasians, the offspring of Vietnamese women and American men.  Speaking at the time of the withdrawal, Richard H. Solomon, assistant secretary of state for East Asian and Pacific affairs, said the pullout “is not enough. After more than a decade of occupation, Hanoi has an obligation to do more than just walk away, leaving Cambodia in a state of civil war.””

[57] Wallace, C. P. (1990, April 29). 15 years after war's end, the U.S. still fights to keep Vietnam isolated: Diplomacy: Washington has linked normalization to help on MIAs and Cambodia. But support for ignoring the war-ravaged nation may be fading. Los Angeles Times. https://www.latimes.com/archives/la-xpm-1990-04-29-mn-300-story.html. “In the last two years, Vietnam has adopted sweeping economic reforms in line with recommendations by IMF experts. It also has tried to arrange international loans to repay $130 million outstanding to the IMF, which technically bars it from seeking new assistance. Washington has blocked the move.  “We’re trying our best to normalize with the IMF, the World Bank and the Asian Development bank,” Nguyen Ngoc Minh, acting director of the external relations department of Vietnam’s central bank, said in a recent interview. “Because of the embargo, we’re facing a real credit squeeze.”  Meanwhile, the Asia Pacific Council of the American Chambers of Commerce, which represents U.S. business interests in 16 Asian countries, adopted a communique at a meeting this month saying it “supports immediate removal of restrictions on U.S. trade and investment with Vietnam. The current economic sanctions severely impact American competitiveness in the region.””

[58] Do, D. D. (2000). Vietnam-United States economic relations. Hanoi: The Gioi Publishers. "The main objective of the United States in carrying out its economic embargo and sanctions against other countries is to alter the activities and policies of the targeted governments in order to force them to follow the US requirements or demands, including the demand to reshape the basic nature of a society's regime and to alter important policies concerning their national security. Richard Haass wrote, 'sanctions can be used for several... purposes: to coerce, to deter, and/or punish... also... for the purpose of persuading the target to alter or cease a specified activity or behavior... to reshape the basic nature of another society or to alter policy in critical areas of another country's or entity's national security' (Haass, pp. 197 and 199). The targeted countries under the US embargo and sanctions have been changed depending on the developments of the world's political situation. Under the Cold War, the main targets of the United States were the communist countries. Since the end of the Cold War, the United States has in its efforts to becoming the leading superpower of the new world order not only directed the main targets of its economic embargo and sanctions on the remaining communist countries in the world, but also other countries including those who used to have good relations with the United States but by now are in the US terms posing the threats of terrorism, drug trafficking, nuclear weapons, or those countries whose governments according to the United States practice dictatorship and violate human rights and democracy. During the period of 1993-1996, the US Government had imposed 22 sanctions concerning human rights and democracy, 14 sanctions for the reasons of anti-terrorism, targeting 13 countries (ND, 13 May 1998). "The main measures and policies implemented by the United States in its embargo and sanctions include the ban on military products, the ban on economic aid, the embargo on investment and foreign trade, the prevention of international financial and economic institutions such as the World Bank (WB), the Asian Development Bank (ADB), the International Monetary Fund (IMF), etc., from provision of loans to the countries under embargo and sanctions." (p. 96-97)

[59] Do, D. D. (2000). Vietnam-United States economic relations. Hanoi: The Gioi Publishers. “"Implementing these laws, acts and regulations, the US Government has imposed an almost comprehensive embargo and sanction policy against Vietnam, including the prohibition of the exchange of visits among citizens between the two countries; the banning of trade and investment of companies from both countries; the punishment on the companies of the third country which have economic relations with the United States and develop commercial transactions with Vietnam; the prevention of international financial institutions like the World Bank (WB), the International Monetary Fund (IMF), Asian Development Bank (ADB) from engaging in economic and financial relations with Vietnam and from providing loans to Vietnam; the blockade or 'freezing' the Vietnamese Government's assets at US banks (in 1994 Vietnam's assets in US banks were of $325 million* and they were blocked by the US Government, meanwhile US companies, most of which were US petroleum companies, asked Vietnam to pay their debts worth of *$208 million)."Nick J. Freeman described the main content of the US Government's embargo against Vietnam, which we think is worth to quote at length here, as follows: "... there are two basic constituent elements to the economic sanctions imposed by the United States on Vietnam. The first is the Foreign Assets Control Regulations pertaining to Vietnam, as authorized under the 1917 Trading With the Enemy Act, commonly termed the US trade embargo. With a few exceptions, all commercial transactions between Vietnam and 'US citizens and permanent residents wherever they are located, all people and organizations physically in the United States, and all branches and subsidiaries of US or organizations throughout the world are illegal under the regulations. The top penalties for violating the sanctions are 12-year imprisonment, $500,000 in corporate fines and $250,000 in individual fines. The trade embargo prevents not only direct and indirect trade between the United States and Vietnam, but also investment by US companies in Vietnam's burgeoning economy. It also has major ripple effects beyond the United States; for example, any product with over 10% US-manufactured content also falls under the embargo restrictions. Consequently, ostensibly non-US multinational firms must also consider the likely consequences that commercial relations with Vietnam may have on their market and operations in America, and a few allied governments - most notably Tokyo - have, at least until recently, tacitly followed the United States ban on private investment in Vietnam. The second basic element of Washington's economic sanctions is its veto on lending by the international financial institutions."” (p. 104-105)

[60] Do, D. D. (2000). Vietnam-United States economic relations. Hanoi: The Gioi Publishers. “Despite the opposition of the secretariats and other member countries, Washington has used its veto to prevent the World Bank, IMF and Asian Development Bank (ADB) from providing financial support on almost all development projects in Vietnam... in urgent need..." (Freeman, p. 14). The overall objective of the United States in their embargo and sanctions against Vietnam is obviously to continue to pursue the aims that they follow during the period of war (1954-1975), that is, to exhaust Vietnam economically and isolate from the outside world, so that by the end Vietnam must follow the conditions imposed by the United States as "to support democratization and... basic human rights" in the American terms (Preeg, p. 4-1).” (p. 105-106)

[61] Do, D. D. (2000). Vietnam-United States economic relations. Hanoi: The Gioi Publishers. “"To the period of 1976-1985, Vietnam faced a large and cumulative deal of difficulties. It had to restore the economy which had been badly damaged during the very long war (several decades under the French and two decades under the Americans) at the same time with the implementation of the new industrialization policy in the context when the aid from socialist countries was falling while the US embargo and sanctions were strengthened. One might notice that the US embargo and sanctions during this period had posed rather drastic effects on Vietnam, turning Vietnam to be more isolated from the world and pulling deeper into the domestic social and economic crisis. During the period of ten years after the War, the social and economic situation in Vietnam had become worse and worse with the triple-digit inflation (700-800% per year) prolonged for many years; the severe shortage of food and consumption goods; the large US aid which had been used to feed the whole consumption society of South Vietnam with over 20 million people was no longer available; industrial and agricultural production and services all went down and were unable to create new jobs; while unemployment became more serious with almost two million employees of the old Saigon Administration and Army lost their jobs and about 1 million youngsters grew up to enter the labor market but failed to find jobs, not yet to mention of a large number of soldiers demobilized; in addition, the economic policies characterized by 'voluntarism' and restrictions on free trade had become the obstacles impeding the development of a multi-sector commodity economy, etc. All these challenges were multiplied by the US embargo and sanctions which prevented Vietnam from approaching the assistances from outside and provoked sabotage from inside, turning the situation from bad to worse. The US embargo during this period was like a sharp knife cutting further and deeper into the wounds of the war which were already hard to heal, now became even harder to heal."” (p. 108-109)

[62] Shah, J. (2025). The imperialist anatomy of sanctions. Denver Journal of International Law and Policy. “Conventional analysis presumes that this assessment of sanctions from the imperial era was left undisturbed by developments in international law during the era of decolonization. It finds confirmation in the frequency with which sanctions have been deployed by the United States “and other developed nations” since World War II and by the ICJ’s 1984 ruling in Military and Paramilitary Activities in and against Nicaragua (“Nicaragua v. United States of America”). The deployment of unilateral economic sanctions is further legitimized as necessary for furthering the goals of morally just international legal regimes such as those protecting human rights. As critical scholars increasingly decry the use of economic sanctions because of the harms such measures cause or contribute to, these scholars sought to set forth analytical frameworks that replace the conventional analysis’s blanket understanding of sanctions as lawful with a more nuanced assessment that could limit their deployment.” (p. 73)

[63] Shah, J. (2025). The imperialist anatomy of sanctions. Denver Journal of International Law and Policy. “Because the economic sanctions at issue in Nicaragua v. United States of America have historically been “the most common” type of sanctions imposed unilaterally, the ICJ’s ruling is often relied upon by conventional legal scholars to support their position that unilateral economic sanctions do not violate the principle of non- intervention. This assertion has two components. First, it is asserted that most unilateral economic sanctions deployed today target matters outside of a state’s domaine réservé, such as human rights, terrorism, and weapons of mass destruction. Using sanctions against human rights violations as an example, the development of international human rights law led to the conclusion that “[t]he principle of state sovereignty does not (any longer) let states decide freely on matters relating to fundamental human rights.” And thus, human rights sanctions are not “directed against the legitimate sovereign political decision- making of a state,” but instead “matters of international concern which justify intervention by the international community.” Second, conventional legal analysis asserts that economic sanctions are inherently non-coercive because to constitute coercion, the measure must be “forcible or dictatorial, or otherwise coercive, in effect depriving the state intervened against of control over the matter in question.” This analysis concludes that because trade relations and economic assistance are “voluntary,” in that “every State can freely decide the manner in which it enters into economic relations with others,” even though economic sanctions “are intended to persuade the target state to pursue, or cease, a particular course of conduct,” they are considered to “fall[ ] short of being dictatorial.’”23 Notably, this conclusion ignores its own broader definition of coercion, which is includes those measures that effectively deprive a state of control over a matter within its domaine réservé.) Even when the designation of coercion is adopted to describe a set of economic sanctions, they are considered lawful simply because the ICJ did not find the U.S.’ sanctions against Nicaragua to violate the principle of non-intervention, with no further explanation.24 Building off this legal analysis, policymakers in former colonizing powers and their settler states, like the European Union and the United States, tend to focus on the non- forcible nature of economic sanctions to justify their use.25 Additionally, with the rise of concepts like “Responsibility to Protect” and “humanitarian intervention” in the 1990s (following the genocides in Rwanda and Bosnia), reaching their peak by the 2010s, conventional analysis has further contended that the flexibility to deploy unilateral economic sanctions is necessary for states to fulfill the goals of the international human rights regime. This view holds that the proliferation of international human rights norms increased the obligations of states to not only respect human rights in the course of their own conduct, but also “take joint and separate action” to ensure human rights are protected everywhere.26 Thus, even if unilateral economic sanctions were considered to violate customary international law, they would be permissible as countermeasures in response to states’ violations of human rights obligations.27 However, this justification is often put forth for specific sets of unilateral sanctions without sufficient analysis to determine whether they comply with the requirements of necessity and proportionality for deploying countermeasures.28 Recent efforts by critical scholars seek to challenge this conventional assessment by identifying legal constraints on the imposition of economic sanctions. These efforts proffer legal assessments that would require examining sanctions on a case-by- case basis to determine whether they violate some specific treaty obligation, such as human rights or trade treaties, or some customary norm governing process, such as immunities or jurisdictional questions.” (p. 74-76)

[64] Shah, J. (2025). The imperialist anatomy of sanctions. Denver Journal of International Law and Policy. “Scholarly analyses of international law traditionally uphold the legality of sanctions, overlooking how they may violate the fundamental right of self-determination as developed by anticolonial lawmaking. This legal framework, born out of anticolonial struggles, encompasses a concept of “non-domination” to safeguard the hard-fought recognition of formerly colonized people’s sovereignty in the form of statehood from ongoing imperialist coercion.” (p. 141)

[65] Getachew, A. (2019). Worldmaking after empire: The rise and fall of self-determination. Princeton University Press. “Against the standard view of decolonization as a moment of nation-­ building in which the anticolonial demand for self-­determination culminated in the rejection of alien rule and the formation of nation-­states, I recast anticolonial nationalism as worldmaking. The central actors of this study reinvented self-­determination reaching beyond its association with the nation to insist that the achievement of this ideal required juridical, political, and economic institutions in the international realm that would secure non- domination. Central to this claim was an expansive account of empire that situated alien rule within international structures of unequal integration and racial hierarchy. On this view, empire was a form of domination that exceeded the bilateral relations of colonizer and colonized. As a result, it required a similarly global anticolonial counterpoint that would undo the hierarchies that facilitated domination. In three different projects—­ the institutionalization of a right to self-determination at the United Nations, the formation of regional federations, and the demand for a New International Economic Order—­ anticolonial nationalists sought to overcome the legal and material manifestations of unequal integration and inaugurate a postimperial world. Attending to these global ambitions of anticolonial nationalism offers opportunities to revisit and rethink the critique of nationalism as parochial and anti-universal. Rather than foreclosing internationalism, the effort to achieve national independence propelled a rethinking of state sovereignty, inspired a far-­reaching reconstitution of the postwar international order, and grounded the twentieth century’s most ambitious vision of global redistribution. In casting anticolonial nationalists as worldmakers rather than solely nation builders, I illustrate that the age of decolonization anticipated and reconfigured our contemporary questions about international political and economic justice.” (p. 2-3)

[66] Getachew, A. (2019). Worldmaking after empire: The rise and fall of self-determination. Princeton University Press. “Anticolonial worldmaking offered a number of strategies to mitigate, circumvent, and undo the hierarchies that facilitated domination. First, through the right to self-­determination, anticolonial nationalists strengthened the legal barriers against foreign intervention and encroachment. Through an expansive account of sovereign equality as equal legislative power and a redefinition of nonintervention that went beyond prohibiting military interventions, anticolonial nationalists sought to contain and limit domination through legal instruments. Second, in the constitution of regional federations in the West Indies and Africa, anti-colonial nationalists sought to evade the economic dependence inherent in the global economy by organizing regional institutions that were egal- itarian and redistributive. Rather than a direct challenge to international hierarchy, federation was an attempt at a partial exit and insulation from the dependencies that facilitated domination. Finally, through the New International Economic Order, anticolonial nationalists directly challenged the economic hierarchies of the international realm. Laying claim to the expansive account of sovereign equality articulated in the right to self-determination, they envisioned an egalitarian welfare world that would be democratic and redistributive. In this final project, nondomination was refigured as a radical form of international equality. Each of these projects offered a different strategy for achieving non- domination, but they were all envisioned as creating the necessary inter- national conditions for postcolonial nation-building. Anticolonial worldmaking was viewed not as an alternative to or rejection of nationalism but instead as a necessary vehicle for securing national independence. Central to this combination of nation-­building and worldmaking was the view that the global project of European empire had radically transformed the economic and political conditions of the modern world in ways that required a similarly global anticolonial project. In its strongest formulation, this argument suggested that the newly independent states were entirely constituted through international political and economic entanglements that could not be escaped or ignored. For instance, Eric Williams and Michael Manley both traced the ways that the Caribbean island states emerged from the institution of colonial plantations. With native peoples and ways of life eradicated in the process of colonization, the Caribbean was reconstituted through the transatlantic slave trade, Indian and Chinese indenture, and colonial trade. As a result, the Caribbean itself was a global formation and could not be disaggregated from the international political and economic relations in which it was embedded. This extreme form of extraversion necessarily required moving beyond national insularity.” (p. 23-24)

[67] Getachew, A. (2019). Worldmaking after empire: The rise and fall of self-determination. Princeton University Press. “With its critical and diagnostic orientation focused on the present configurations of international hierarchy, the normative and utopian core of a postcolonial cosmopolitanism remains the principle of nondomination at the center of anticolonial worldmaking. Nondomination recasts the current configurations of international hierarchy as infringements on collective projects of self-­government. This approach contrasts with an account of the injustices of the international sphere that is primarily concerned with the violation of individual human rights. While international human rights protections have provided important resources in challenging international hierarchy and can be combined with collective claims for self-­government, on their own they offer a limited account of the wrongs involved. For instance, the expansive claims of private corporations not only undermine individual human rights but also threaten the capacity of self-­government insofar as corporate prerogatives erode guarantees secured through state constitutions and national legislation. An emphasis on nondomination thus broadens our account of the injustices that unequal integration and international hierarchy engender. Moreover, as the examples of anticolonial worldmaking suggest, realizing the international condition of nondomination necessary to self-­ government can extend beyond a defense of the state to include more demanding internationalisms.” (p. 33)

[68] Getachew, A. (2019). Worldmaking after empire: The rise and fall of self-determination. Princeton University Press. “This is not an argument for retreating into a defensive sovereigntist position, which cannot provide adequate critical and normative resources to address the contemporary dilemmas of the international order, and it should be clear that the postcolonial approach outlined here does not offer an exhaustive theory of the international order. But in returning to the problem of empire, it provides a readjustment of what we take to be the central conundrums and predicaments of international politics. Moreover, it reminds us that claims of sovereignty and sovereign equality not only have preserved the state against claims of international justice by creating a hermetic seal but also have served as the foundation of anti-­ imperial visions of international justice. These principles provide bulwarks against hierarchy and resources for resisting domination in the international sphere, while also making possible ambitious visions of the international redistribution of political and economic power.” (p. 34)

[69] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “US financial sanctions have been described as having a “crippling” effect.  One recent target, the head of a Russian aluminum company, described America’s sanctions capability as a “devastating power. ” What is the secret behind the punch that US financial sanctions pack? According to former treasury secretary Jack Lew, the United States owes these capabilities to “the predominant role that the US financial system plays in global commerce. ” It is precisely because the world economy relies so heavily on the dollar, and the American financial institutions through which those dollars flow, that US sanctions are so potent. Yet despite—or perhaps because of—this potency, overusing sanctions incentivizes targeted and at-risk governments to reduce their dependence on the dollar-based financial system. This suggests two important implications for consideration. First, the more the United States uses its devastating power, the less devastating it will become in time. Second, politics—not just economic fundamentals—is central to the dollar’s appeal as an international currency.” (p. 36)

[70] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “Many scholars argue that political factors play a key role in sustaining the dollar’s global dominance. A central claim is that U.S. foreign policy creates expectations of diffuse benefits for certain foreign governments, which in turn bolsters the dollar’s international appeal. States that align with or support America’s activist global posture may gain—albeit indirectly—by reinforcing the dollar’s prominence. A common variant of this argument highlights that official foreign holdings of dollar assets, particularly U.S. Treasury bills, function effectively as loans to the U.S. government. By supporting the dollar’s reserve status, allied governments help finance U.S. defense spending, thereby enabling Washington to maintain a more assertive global military stance. As Jonathan Kirshner put it, the dollar’s reserve role has “made it easier for [the United States] to pursue an ambitious and often costly grand strategy.” From this logic, governments that view U.S. military power and broader foreign policy objectives as indirectly serving their own national interests should, all else being equal, adopt pro-dollar policies—most notably, by holding a larger share of their foreign exchange reserves in dollars. Consistent with this view, numerous studies find that U.S. military allies tend to be strong dollar supporters, ostensibly because they benefit from the positive security externalities that come with dollar holdings.” (p. 38-39)

[71] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “Theories about the political foundations of international currency status have typically emphasized the ways in which foreign policy helps a currency climb up the global currency hierarchy or maintain dominance. My theory seeks to unify these ideas with a set of emerging claims informed by unfolding events in world politics. The notion that political factors have a universally positive impact on a currency’s international appeal is misguided. The policy actions of the issuing state may enhance the attractiveness of its currency for international use or harm it by influencing expectations about the future costs or benefits associated with the currency. When the United States wields the dollar as a weapon against its adversaries, this weakens its appeal as an international reserve currency and cross-border medium of exchange. And the more it uses financial sanctions, the more non-sanctioned states with interests in conflict with Washington are likely to worry that they will face similar measures in the future. Over time, a subset of states may seek to minimize their reliance on a currency that leaves them vulnerable to coercion.” (p. 46-47)

[72] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “In their seminal study of the weaponization of economic interdependence, Henry Farrell and Abraham Newman explain how states that control key hubs in global networks gain “considerable coercive power. ” Such privileged states can cut adversaries out of the network by limiting their access to the hub. This “chokepoint effect” levies serious costs on its targets. 22 The dollar’s pre-eminence as an international store of value and medium of exchange is the foundation of the United States’ capacity to employ chokepoint effects against foreign adversaries by applying financial sanctions. As noted above, 40 to 45 percent of all cross-border payments involve the US dollar, and 96 percent of cross-border, dollar-denominated payments involve a CHIPS participant institution as an intermediary. While not all CHIPS participants are American banks, they are all required to have a US branch. 23 Thus the select group of CHIPS correspondent banks, which effectively facilitate the clearing of all dollar payments in the global financial system, are collectively subject to US law. This jurisdictional control over the flow of dollars in the global economy gives the United States the immense power to levy crippling sanctions against its adversaries. In the remainder of this section, I discuss the two main types, primary and secondary sanctions. Most financial sanctions can be categorized as pri mar y sanct i ons. These measures are designed to cut the targeted individual, firm, or government off from the dollar-based financial system. ” (61-62)

[73] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “Any entity designated an SDN will find it nearly impossible to locate a bank with US operations willing to conduct business on its behalf. This includes all CHIPS participant banks, which are involved as correspondent institutions in nearly all cross-border dollar clearing operations. Thus, being placed on the SDN list results in near total isolation from the dollar-based financial system; SDNs will find it very difficult to service foreign debts, purchase or sell foreign assets, or finance cross-border trade using dollars. If an SDN holds dollar- denominated assets at an institution with US operations, Treasury can also compel the bank to freeze those funds, effectively taking possession of the SDN’s wealth. The economic costs of being designated a target by OFAC are enormous.” (p. 64-65)

[74] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “The US government often employs financial sanctions against individuals or entities linked to non-state groups like terrorist organizations and criminal networks. Washington also uses them to target actors associated with foreign governments. Financial sanctions—sometimes called “smart sanctions”—can precisely target rogue regimes. Whereas trade sanctions, like embargos, result in significant costs for an entire population in a foreign country, financial sanctions can be designed to cause less collateral damage. Yet, while these “smart” sanctions may target individuals or firms, the strategic target is usually the regime to which these entities are linked. Since the turn of the century, the United States has used its financial sanctions capabilities more frequently, targeting more foreign SDNs—and the governments to which many are tied—than ever before. The use of financial sanctions became especially common during the Obama and Trump administrations. As sanctions expert Daniel Drezner explains, financial sanctions became the “go-to solution for nearly every foreign policy problem. ” The typical way that Treasury is ordered to enforce a new sanctions program related to a set of SDNs is through an Executive Order issued by the president. The total number of sanctions-related Executive Orders (SREOs) increased by nearly 500 percent, from just twenty-two in the year 2000 to ninety-four by the end of 2020.  Figure 2.5 depicts the steady increase in SREOs during this period. While a small number of SREOs were revoked during this period, far more new measures were added.  During the twenty years covered in Figure 2.5, the total number of active SREOs decreased only twice, and then only marginally, before rising again.” (69-70)

[75] McDowell, D. (2023). Bucking the buck: U.S. financial sanctions and the international backlash against the dollar. Oxford University Press. “Governments hold US government debt because they are confident these bonds can be converted into cash at a moment’s notice. 17 The third and final type of risk is that the income derived from an investment in one currency will fall relative to potential investments in alternative currencies due to exchange rate movements (currenc y ri sk ). The dollar’s value fluctuates like that of any currency with a market-driven, floating exchange rate. Thus, there are times when a country’s foreign exchange reserves may have performed better if they were held in another currency. 18 Yet overall, the dollar is widely viewed as having a stable value that is backed by sound economic management. Of course, one goal of this book is to point out that economic risks are not the only thing that central bankers worry about these days. When the Libyan Central Bank discovered that the US Treasury had frozen nearly $40 billion of its assets, it learned that dollar- denominated assets could become illiquid at the stroke of the US president’s pen. As noted in the previous chapter, most central banks hold a significant share of their dollar reserves in accounts with the Federal Reserve Bank of New York; it provides “custody and safekeeping, and investment services” to nearly all foreign central banks, big or small. Most of the official accounts maintained at the New York Fed are in the form of US Treasury bonds, but it also houses large amounts of foreign monetary gold as a service to foreign governments. 19 All assets held in New York are quite literally at risk of being locked up by an OFAC directive, as are any other assets held in commercial banks with US operations—a group that includes virtually every major global bank. The more that Washington demonstrates its capacity and willingness to freeze foreign governments’ assets, the more likely it is that political risk will be a major concern for governments and central banks with sizable dollar holdings. ” (p. 86)

[76] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. “As critical political economists and political theorists have noted, this reality has profound consequences for monetary sovereignty. States nominally retain the right to issue their own currency, but they de facto (and at times, de jure) rule over jurisdictions that rely on currencies issued by other sovereigns, and especially the United States, for a broad range of transactions. This problem has mostly escaped the attention of Third World Approaches to International Law (TWAIL) and other critical international legal scholars. Indeed, juridical critiques of the international financial system have mostly coalesced around conditionalities attached to loans by international financial institutions, rather than the fact that both their loans and the global financial system, in general, are dominated by the currency of one sovereign, the United States of America. In contrast, the United States has been increasingly proactive in mobilizing the powers afforded to it by dollar hegemony in order to achieve a wide range of foreign policy goals. Modern sanctions, in fact, constitute one of the most important manifestations of the weaponization of dollar hegemony for the furtherance of U.S. interests. Over the past fifteen years, the United States switched the modality of its sanctions from “traditional” trade embargoes, such as those imposed on Cuba, to financial sanctions that target transactions through, or assets held in, the U.S. banking system. Numerous states, including Iran, Venezuela, and Russia, have been targeted with financial sanctions. In particular, the case of Russia has triggered extensive political and legal debates concerning the possibility of confiscating assets of the Russian central bank in order to pay reparations to Ukraine in light of Russia’s aggression. These important debates address questions central to this paper, which focuses on Afghanistan.” (p. 2-3)

[77] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. “This is not simply a case of competing entities claiming to be the government of a state, a scenario that is hardly novel. Rather, a body that does not claim to be the government of a state was vested with certain governmental functions concerning price and currency stability and granted access to state assets in a way that disaggregates Afghanistan’s governmental functions and sovereign authority. In other words, the United States has used its currency power and the rhetoric of humanitarian concerns to reconfigure the governmental structure of a sovereign state in ways that directly contravene even the most minimalist constructions of the rule of non- intervention. The idea that a state can slice up another’s governmental functions and allocate them to actors of its choosing undermines the very foundation of a binding international legal order. My analysis proceeds in three steps. First, I will offer a brief overview of the origins and contemporary reality of dollar hegemony and its instrumentalization in the context of financial sanctions. Second, I will present the international legal issues raised by the practice of central bank asset freezing with an emphasis on state immunity and government recognition with a particular reference to the Fund. Finally, I will show the uniquely ambitious nature of sanctions against Afghanistan and the worldmaking implications of the Afghan Fund. My argument is that even though the Fund remains paralyzed due to internal disagreements about its functions, its very existence constitutes a challenge to the concept of Third World sovereignty.” (p. 5)

[78] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. “Despite this relative inactivity, the sheer existence of the Afghan Fund further complicates ongoing debates about the legality of the increasingly utilized practice of freezing central bank assets. My argument here is that these doctrinal debates need to be situated within the broader context of dollar hegemony. The predominance of the U.S. dollar gives the United States extensive de facto (if not necessarily de jure) law-making power in certain areas of international law, including the law of state immunity. Put simply, customary international law dictates that states cannot be subjected to the judgment and execution of foreign courts (more on this shortly) provided that the act in question is a manifestation of sovereign power (acta jure imperii) and not of commercial nature (acta jure gestionis). Therefore, foreign central bank reserves should be almost entirely protected under this arrangement. However, recent practice shows that the United States—although reluctant to seize these central bank assets outright—has triggered an extensive practice of freezing or redirecting them and, as I will show below, relying on unorthodox international legal arguments to justify its practice This brings me to the crux of my argument: TWAIL scholars have placed the dynamics of imperialism at the core of international law, showing how the function of our field is not (primarily) to create order between equal sovereigns but to manage imperial expansion. Robert Knox has refined this position by arguing that this centrality of imperialism entails not only the regulation of center-periphery dynamics but also the interactions between different imperial powers themselves. His argument is that in formulating legal arguments and adopting legal practices, imperial powers (and their scholarly outposts) attempt a dual move: first, to subjugate weaker states and secondly, to ensure that their geopolitical rivals cannot use the same arguments and practices to promote their own imperial interests. The nominal universality of international law means that when using a specific legal argument, the United States needs to either find a way to exclude China or Russia from doing the same or accept the availability of this argument to its rivals. The invocation of “humanitarian intervention” by Russia to justify its use of force in Ukraine from 2014 onwards is an example of the danger that international law arguments might spread beyond their intended sphere of application. Similarly, the reluctance on behalf of some parts of the U.S. state apparatus to cooperate with the International Criminal Court in its pursuit of cases against Vladimir Putin and Maria Alekseyevna Lvova-Belova indicates a concern that this case might (against all odds) set a precedent in regards to the nationals of other third-party states, which notoriously include the United States. In a nutshell, the existence of plausible imperial rivals places limitations on the legal rights that the United States claims for itself, especially since the end of its undisputed geopolitical and legal hegemony in the immediate aftermath of the Cold War. This concern about the potential future invocation of legal arguments by other powers applies in modified ways when it comes to financial sanctions and other forms of dollar weaponization. The unique position of the United States within the global monetary system means that there is simply no reciprocity of exposure here. This is the case not only in regard to the United States’ relationship with Afghanistan or Venezuela but also in its relationship with China and Russia. As a result, the United States enjoys two unique privileges when it comes to law-making regarding state immunity.” (p. 14-15)

[79] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. “TWAIL and scholars sympathetic to the Global South have repeatedly criticized the disproportionate weight given to Western state practice and opinio juris by both courts and international legal scholarship.84 There is no doubt that there are numerous disciplinary, institutional, and cognitive biases against Global South states (and in favor of Global North states) in international law. However, what is sometimes missed from these debates is an understanding that impactful biases do not exist primarily in the sphere of ideas or the minds of lawyers but that they are grounded in material power: as long as national currencies operate as global currencies, the state(s) that issue these currencies will yield disproportionate power in the lawmaking concerning state immunities and, by implication, in the lawmaking concerning sanctions.85. This is not to say that idiosyncratic interpretations of U.S. officials and scholars are correct according to some principled standard of assessment. However, it does mean that dollar hegemony allows the United States to produce a disproportionate amount of state practice when it comes to sanctions and, in the absence of rigorous contestation, legal argumentation that justifies this practice might become entrenched not due to its finesse or logical prowess but because it seeks to rationalize a socially dominant dynamic, namely the weaponization of the dollar.” (p. 18)

[80] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. “TWAIL scholars have always been ambivalent vis-a-vis state sovereignty.86 On the one hand, TWAIL emerged as an intellectual movement during the 1990s,87 at a time when critiques of sovereignty were used to justify projects of military and economic interventionism against Global South states.88 In this context, pronouncing sovereignty to be obsolete or politically or morally suspicious did not lead to questioning the prerogative of Global North states to maintain and deploy military forces—a sign of old-school sovereignty if there was ever one—but rather, attempted to remove argumentative barriers against the extraterritorial projection of certain states’ sovereign power.89 In the realm of economic policy, anti-sovereignty arguments were regularly deployed to curtail states’ abilities to enact redistributive agendas, restrict the flows of capital, and regulate transnational and domestic capital.90 In this intellectual climate, it was—and remains—tempting to assert Global South sovereignty, if not as the encapsulation of a comprehensive political program of liberation, at least as a shield against imperialism and neoliberal capitalism. This is not an unprecedented move: as post-colonial states gained independence, the language of sovereignty was indispensable both in asserting themselves in global law and politics and, as Adom Getachew has shown, in attempting to reform international relations along more equitable lines.91 In Getachew’s telling, the more radical leaders of post-colonial states did not envisage their states’ hard- won sovereignty as the end of the decolonizing process but as a means through which they could question and, eventually, remake international economic” (p. 19)

[81] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. “Even before the 1980s, invocations of state sovereignty were often mobilized to justify authoritarian forms of government, the suppression of minorities, and state-building projects that were hostile towards indigenous peoples and anyone who did not fit into the nationalist-developmentalist project.94 More broadly, TWAIL scholars have been ambivalent about the post- colonial state’s attempts to emulate what they consider Eurocentric concepts of sovereignty, with a particular and crucial emphasis on the dangers of thinking of sovereignty as a form of mastery over nature. Scholars such as Natarajan, Pahuja, and Nesiah (perhaps not coincidentally some of the leading women of TWAIL) have noted that in asserting permanent sovereignty over natural resources, Third World states questioned who should assert control over and reap the benefits of resource extraction, while simultaneously affirming the ideas of nature as “natural resources” that ought to be exploited to the maximum and of sovereignty as boundless extraction and expansion.95 When it comes to international law in particular, TWAIL and other heterodox scholars have documented that the gradation and conditioning of Third World sovereignty has been anything but aberrational in the history of international law and politics. In this telling, international law itself has been ambivalent toward Southern sovereignty since affirmations of sovereign equality have always co-existed with postponements or conditioning of equal rights, duties, and status.” (p. 20)

[82] Tzouvala, N. (2024). Sanctions, dollar hegemony, and the unraveling of Third World sovereignty. Yale Journal of International Law, 49(Symposium Issue). https://yjil.yale.edu/posts/2024-06-10-sanctions-dollar-hegemony-and-the-unraveling-of-third-world-sovereignty. Secondly, it is not uncommon for states to disagree about a state’s government but nevertheless accept the unity of such government and, by extension, the sovereign authority of the state understood as a unified entity for the purposes of international law. Indeed, a unified and effective government is a (arguably the) precondition for an entity to be a state under international law. Admittedly, this idea of a coherent government in control of the state has always been fiction. This is especially the case in the Global South, where legal pluralism and layered forms of political authority continue to prevail, with formal governmental power and state law having varying degrees of effectiveness and legitimacy depending on one’s location, profession, gender, religion, etc. This fiction, though, underlies international law as we know it. The Afghan Fund diverges from this conceptualization and general state practice in regard to government recognition. It is not recognized as Afghanistan’s government by the United States, nor does it claim to be such a government. Yet, it is considered to act for the benefit of the Afghan people, with the sole purpose of managing and disbursing DAB’s frozen assets. In essence, the Fund disaggregates Afghanistan’s governmental functions, opening up the possibility of different actors being recognized as representatives of a state/people for different purposes. In this respect, citing Venezuela as a precedent for the practice, as Brunk does, elides its novelty and, crucially, its incompatibility with Afghanistan’s sovereignty. If taken to its logical conclusion, the practice is not only incompatible with Third World sovereignty but with the very idea of binding international legal obligations: (powerful) states would be free to recognize virtually any entity as representative of a people/state for the sole purpose of obtaining its consent for the use of force, entering/denouncing treaties, or transferring to it state assets despite state immunity. (p. 22-23) 

[83] Tan, D. (2025). The decoupling dilemma: How US sanctions erode global economic governance. International Organization, 79(4), 1–20. https://doi.org/10.1017/S0020818325100994. “This pivot toward dollar-clearing chokepoints and correspondent-banking exclusion reflects America’s confidence in networked leverage: by weaponizing access to SWIFT, dollar liquidity, and capital markets, Washington assumed it could inflict targeted pressure without triggering major retaliation. Yet that very confidence has sown a backlash against US gatekeeping power. Rival states and firms have not passively absorbed these costs but rather mobilized a battery of countermeasures— central bank digital currencies, bilateral swap lines, gold accumulation, and barter networks—all aimed at creating“valves” around US-led infrastructure.” (p. 134-135)

[84] Tan, D. (2025). The decoupling dilemma: How US sanctions erode global economic governance. International Organization, 79(4), 1–20. https://doi.org/10.1017/S0020818325100994. “One need only look at China’s Cross-Border Interbank Payment System (CIPS) to see this logic in action: what began as an RMB settlement channel has rapidly grown into a partial SWIFT alternative, adopted by over 4,900 banking institutions in 187 jurisdictions.3 Simultaneously, sanctioned economies like Russia, Iran, and Venezuela have diversified reserves, launched domestic payment schemes, and rewired supply chains to reduce reliance on US-controlled rails. These adaptations not only blunt the impact of individual sanctions but also form emergent parallel ecosystems—regional currency blocs, BRICS institutions, and normative claims to economic sovereignty—that challenge dollar primacy on a systemic level even as the dollar remains dominant in reserves and foreign exchange markets. This unfolding paradox—where the tools intended to project US influence instead catalyze institutional decoupling—raises a fundamental question: How do sanctions reshape global governance? Beyond simple cost-benefit logic, this essay draws on structural power and institutionalist insights—extending classic accounts of complex interdependence and engaging recent work on monetary power and sanctions —to trace the dynamic interplay between coercion and adaptation.” (p. 135)

[85] Tan, D. (2025). The decoupling dilemma: How US sanctions erode global economic governance. International Organization, 79(4), 1–20. https://doi.org/10.1017/S0020818325100994. “Over the last decade, scholars have extended this logic by highlighting the networked nature of the global economy—trade flows, financial messaging, and overlapping regulations—that shapes states’ leverage.8 Overlapping jurisdictions and dense institutional linkages generate both opportunities and vulnerabilities. When national regulations collide—on issues ranging from accounting standards to export controls—actors can form transnational coalitions that reshape domestic institutions and contest global norms.9 This“new interdependence” shows why sanctions can inflict damage beyond what simple cost-benefit logic predicts. Building on this, weaponized interdependence argues that states occupying central “hub” positions in global networks—such as US dominance over the dollar payments system, SWIFT, and major capital markets—gain two asymmetric advantages: the panopticon effect, which allows monitoring and intelligence gathering, and the chokepoint effect, which enables targeted states to be cut off from essential services.” (p. 136)

[86] Tan, D. (2025). The decoupling dilemma: How US sanctions erode global economic governance. International Organization, 79(4), 1–20. https://doi.org/10.1017/S0020818325100994. “In an age when traditional military options yield high risks and diminishing returns, states increasingly turn to economic coercion to preserve or enhance relative advantage and to exploit monetary centrality.11 Yet weaponizing interdependence entails its own fragility: when states rely heavily on disrupting financial or trade chokepoints, they create the very incentives for rivals to develop counter-hegemonic architectures and to“sanctions-proof” key transactions, prompting a spectrum of coping strategies. For analytic clarity, these strategies can be grouped into three forms: evasion (one- off concealment to complete a transaction), adaptation (operational workarounds that preserve dependence on existing rails), and governance decoupling (the deliberate construction of alternative rules, venues, and payment rails that reduce exposure to US chokepoints). These forms lie on an investment–institutionalization continuum: evasion is episodic, adaptation routinizes workarounds on existing rails, and governance decoupling institutionalizes alternative rules and payment rails. Because only the last alters underlying dependence, it is most likely under three scope conditions. First, actors must possess—or be able to manufacture over time—credible outside options: repeated coercion can turn demand for alternatives into actual supply.12 Second, switching costs are heterogeneous across domains: reserve- currency functions are far stickier than supply chains, slowing substitution at the monetary core while enabling earlier shifts in trade and finance plumbing.13 Third, policy feedbacks harden workaround investments into institutions: once firms and states internalize the value of redundancy, complementary rules and infrastructures accumulate, making reversion less likely even if sanctions abate.14 Under these conditions, each sanction episode raises the expected return to investing in alternatives, pushing the system from transactional evasion toward persistent network reconfiguration. Consequently, pressures can accumulate toward governance decoupling: rather than episodic evasion, targets begin to institutionalize redundancy and partial exit from US-led arrangements. Once a state perceives that continued participation in US- dominated systems poses an existential risk, it seeks alternative payment rails (such as China’s CIPS), regional currency swaps, and digital currencies. Related diversification has also been driven by dissatisfaction with US-led financial governance and the search for non-IMF options, which has bolstered support for China’s economic leadership.15 Jurisdictional expansion—through internal regulatory harmonization within the European Union or coordinated BRICS fintech standards—further diminishes vulnerability to US extraterritorial measures” (p. 137)

[87] Tan, D. (2025). The decoupling dilemma: How US sanctions erode global economic governance. International Organization, 79(4), 1–20. https://doi.org/10.1017/S0020818325100994. “As repeated US sanctions interact with broader shifts—China’s rise and recent volatility in US commitments to liberal rules—global economic governance stands at a crossroads. The core question is whether the future holds a bifurcation into rival economic blocs or a pluralistic coexistence of interoperable systems. On the one hand, bifurcation is plausible. As China, the BRICS countries, and other regional coalitions consolidate payment platforms and legal regimes independent of dollar- centric mechanisms, incentives to remain connected to US chokepoints diminish. Over time, separate spheres of finance and trade could crystallize, with firms and states choosing one bloc’s clearinghouses, dispute-resolution norms, and settlement currencies over the other. In that scenario, parallel orders would evolve in relative isolation—effectively erecting economic“curtains” that limit cross-bloc integration and force states to navigate dueling sets of rules depending on their chosen alliances.” (p. 143)

[87] Tan, D. (2025). The decoupling dilemma: How US sanctions erode global economic governance. International Organization, 79(4), 1–20. https://doi.org/10.1017/S0020818325100994. “If sanctions in a unipolar era served as powerful levers to impose costs without triggering full-scale war, their utility in a post-unipolar order is more conditional. As more actors develop their own valves and alternative channels—whether through digital tokens, regional swap lines, or parallel supranational courts—the marginal returns on US sanctions can decline. Every additional round of financial pressure may yield less raw leverage because the number of firms and states capable of rerouting transactions around chokepoints steadily grows. In effect, the sanctioning state confronts diminishing returns: the first wave of targeted financial exclusion may still inflict genuine hardship on a regime that lacks recourse, but by the third or fourth round, that same regime and its commercial partners have likely woven a denser web of alternatives. This evolving landscape calls on IR scholarship to integrate backfire logic explicitly into theory. Traditional models of sanction effectiveness often assume that if targeted costs can be raised or varied sufficiently, the desired political outcome will follow. Yet the empirical record suggests otherwise: demand for alternatives can gradually create supply. This“backlash” dynamic is consistent with McDowell’s account of how repeated sanctions reshape expectations about dollar risk and, over time, nudge institutional change even without dramatic shifts at the core. When coercive measures themselves drive institutional innovation, they tend to shift the balance of structural power rather than secure compliance. A mature research agenda must therefore move beyond simple cost-benefit calculations to examine how repeated sanctions reshape—and sometimes erode—the underlying networks they leverage. Conceptual frameworks that treat sanctions as static“sticks” miss the dynamic, reflexive process by which targets and allies co-construct alternative orders in response. Finally, anticipating the institutional legacies of economic coercion is imperative. Today’s sanctions leave more than economic pain; they incentivize sanctioned regimes and their partners to invest in durable parallel infrastructures and alternative legal standards that outlive any individual sanctions episode. Each round of coercion can durably reshape the global governance architecture, embedding new rules and norms into international relations. To navigate this reality, policymakers and scholars alike must develop a forward-looking understanding of how coercive episodes catalyze structural change—an understanding that acknowledges sanctions’ paradoxical power to undermine the very order they intend to uphold. Only by anticipating these legacies can we reimagine coercion in a world where reliance on a single hegemonic currency and unified regulatory institutions is increasingly contested.” (p. 144)

[88] Hickel, J., & Sullivan, D. (2025, August 6). The real reason the West is warmongering against China. Jason Hickel. https://www.jasonhickel.org/blog/2025/8/6/the-real-reason-the-west-is-warmongering-against-china. “Over the past two decades, the posture of the United States toward China has evolved from economic cooperation to outright antagonism. US media outlets and politicians have engaged in persistent anti-China rhetoric, while the US government has imposed trade restrictions and sanctions on China and pursued military buildup close to Chinese territory. Washington wants people to believe that China poses a threat. China’s rise indeed threatens US interests, but not in the way the US political elite seeks to frame it. The US relationship with China needs to be understood in the context of the capitalist world-system. Capital accumulation in the core states, often glossed as the “Global North”, depends on cheap labour and cheap resources from the periphery and semi-periphery, the so-called “Global South”. This arrangement is crucial to ensuring high profits for the multinational firms that dominate global supply chains. The systematic price disparity between the core and periphery also enables the core to achieve a large net- appropriation of value from the periphery through unequal exchange in international trade.”

[89] Hickel, J., & Sullivan, D. (2025, August 6). The real reason the West is warmongering against China. Jason Hickel. https://www.jasonhickel.org/blog/2025/8/6/the-real-reason-the-west-is-warmongering-against-china. “Given all this, capitalists in the core states are now desperate to do something to restore their access to cheap labour and resources. One option – increasingly promoted by the Western business press – is to relocate industrial production to other parts of Asia where wages are cheaper. But this is costly in terms of lost production, the need to find new staff, and other supply chain disruptions. The other option is to force Chinese wages back down. Hence the attempts by the United States to undermine the Chinese government and destabilise the Chinese economy - including through economic warfare and the constant threat of military escalation. Ironically, Western governments sometimes justify their opposition to China on the grounds that China’s exports are too cheap. It is often claimed that China “cheats” in international trade, by artificially suppressing the exchange rate for its currency, the renminbi. The problem with this argument, however, is that China abandoned this policy around a decade ago. As the economist Jose Antonio Ocampo noted in 2017, “in recent years, China has rather been making efforts to avoid a depreciation of the renminbi, sacrificing a large amount of reserves. This may imply that, if anything, this currency is now overvalued.” China did eventually permit a devaluation in 2019, when tariffs imposed by the Trump administrated increased pressure on the renminbi. But this was a normal response to a change in market conditions, not an attempt to suppress the renminbi below its market rate.”

[90] Hickel, J., & Sullivan, D. (2025, August 6). The real reason the West is warmongering against China. Jason Hickel. https://www.jasonhickel.org/blog/2025/8/6/the-real-reason-the-west-is-warmongering-against-china.  “The second element that’s driving US hostility toward China is technology. Beijing has used industrial policy to prioritise technological development in strategic sectors over the past decade, and has achieved remarkable progress. It now has the world’s largest high-speed rail network, manufactures its own commercial aircraft, leads the world on renewable energy technology and electric vehicles, and enjoys advanced medical technology, smartphone technology, microchip production, artificial intelligence, etc. The tech news coming out of China has been dizzying. These are achievements that we only expect from high-income countries, and China is doing it with almost 80 percent less GDP per capita than the average “advanced economy”. It is unprecedented. This poses a problem for the core states because one of the main pillars of the imperial arrangement is that they need to maintain a monopoly over necessary technologies like capital goods, medicines, computers, aircraft and so on. This forces the “Global South” into a position of dependency, so they are forced to export large quantities of their cheapened resources in order to obtain these necessary technologies. This is what sustains the core’s net-appropriation through unequal exchange China’s technological development is now breaking Western monopolies, and may give other developing countries alternative suppliers for necessary goods at more affordable prices. This poses a fundamental challenge to the imperial arrangement and unequal exchange.”

[91] Hickel, J., & Sullivan, D. (2025, August 6). The real reason the West is warmongering against China. Jason Hickel. https://www.jasonhickel.org/blog/2025/8/6/the-real-reason-the-west-is-warmongering-against-china. “The US has responded by imposing sanctions designed to cripple China’s technological development. So far this has not worked; if anything, it has increased incentives for China to develop sovereign technological capacities. With this weapon mostly neutralised, the US wants to resort to warmongering, the main objective of which would be to destroy China’s industrial base, and divert China’s investment capital and productive capacities toward defence. The US wants to go to war with China not because China poses some kind of military threat to the American people, but because Chinese development undermines the interests of imperial capital.”

[92] Hickel, J., & Sullivan, D. (2025, August 6). The real reason the West is warmongering against China. Jason Hickel. https://www.jasonhickel.org/blog/2025/8/6/the-real-reason-the-west-is-warmongering-against-china. “The real reason for Western warmongering is because China is achieving sovereign development and this is undermining the imperial arrangement on which Western capital accumulation depends. The West will not let global economic power slip from its hands so easily.”