Figure 4: Gender of Syrians targeted with EU and US sanctions

As part of the data enrichment process, we identified targeted individuals’ whereabouts. We found that 14.1% of them (51 individuals) live or spend substantial periods of time abroad. Of those 51 individuals, 18 are Syrian, shedding light on the sanctions’ reach beyond Syria’s borders. Some of these names include:

• Wael Abdulkarim and Ahmad Barqawi, who were listed along with their Syria and Dubai-based companies for their involvement in facilitating the shipment of aviation fuel to the Assad regime.[30]

• Mudalal Khuri, who assisted sanctioned entities and managed business and financial interests in Russia for the Syrian regime.[31] He was recently linked to the company that bought the ammonium nitrate that exploded at Beirut’s port in August 2020.[32]

• The family members of Bashar al-Assad’s wife, Asma al-Assad (née Asma al-Akhras): Sahar Otri al-Akhras, Firas al-Akhras, and Eyad al-Akhras.[33]  

Figure 5: EU/US-Sanctioned individuals based on their place of living, within or outside Syria

Thirty-three of the 51 individuals living abroad are not Syrian; many are originally from Lebanon, Iran, and Turkey. There are also targeted individuals of other nationalities, such as Russia, the Netherlands, Cyprus, China, and Germany, most of whom are businessmen. The Caesar Act made secondary sanctions easier to impose, to exert greater pressure on the Syrian regime by tracing its third-party affiliates.

​

Over the years, the Syrian regime has engineered sophisticated international networks to help it evade sanctions. In a recent interview with Firas Tlass, the son of Mustafa Tlass, Syria’s former minister of defense, he mentioned how smoothly the transition of wealth was completed from the Makhlouf family to Assad family members, within their European and Gulf Cooperation Council (GCC)-based accounts, after the recent spat between the families. 

This was achieved through a sophisticated network of business ownership schemes designed by Lebanese, English, and South African lawyers.

[34]

​

We do not have a comparable reference point against which to benchmark the 51 individuals living abroad, but given our perception of the spread of the regime’s network, we believe that cross-border and secondary sanctions are significantly underutilized. This is affirmed when we see that 46 of the 51 we identified were sanctioned by the US alone (during November 2014-November 2015 and December 2016-December 2017), four were sanctioned by the EU alone, and only one was sanctioned by both. Moreover, section 5.1 of this study discusses an additional point supporting this belief.

​

From a legal point of view, secondary sanctions in the case of Syria are a very powerful tool in terms of their coverage and application. Section 7412(a)(2)(A)(iii) of the National Defense Authorization Act 2020 shows that secondary sanctions apply to “the foreign person [who] (A) knowingly provides significant financial, material, or technological support to, or knowingly engages in a significant transaction with ... (iii) a foreign person subject to sanctions pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) with respect to Syria or any other provision of law that imposes sanctions with respect to Syria.”[35] In other words, apart from committing sanctionable behavior, a non-US person who has significant dealings with any sanctioned individual or entity on Syria’s SDN list can be sanctioned, too. 

We believe that if the secondary sanctions become more transparent and collaborative, their effectiveness can be greatly improved with the support of individuals and watchdog organizations in the Syrian diaspora. This point will be discussed further in the following sections.

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Shortcomings of the Current Sanctions

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Now that we have provided a history of US/EU sanctions and highlighted key data findings, we will assess the shortcomings of the current sanctions imposed on the Syrian regime. We will analyze both US and EU sanctions in light of our data collection and desk review, and argue that the effectiveness of the current US/EU framework can be significantly enhanced by overcoming several issues.

The targeted individuals

When analyzing the sanctioned individuals, we found that most are already deeply rooted in the Assad regime. This fact hinders the primary goal of the sanctions: behavioral change. Instead, being targeted positively feeds these individuals’ ideological narrative in front of their supporters, strengthening rather than weakening their position within the regime. Furthermore, sanctions push them closer toward the regime and probably improve their chances of winning economic opportunities within Syria and accumulating capital, because they are no longer welcomed internationally.

​

Some individuals in Syria have even proclaimed their gratitude for being targeted by global sanctions — it proves how patriotic they are — and affirmed the “sacrifices” they have made to stand firm in the face of global conspiracies and imperialist attacks. One example is businessman Wasim Qattan,[36] who responded to EU and US sanctions imposed on him by saying, “I had the honor of my name, Wasim Qattan, being included in the list of businessmen under European sanctions.”[37]

We believe sanctions should not stop at those deeply rooted in the regime, but should consider less entrenched individuals as well, like those with lower ranks in the formal chain of command, primarily because they are more likely to change behavior. Generally speaking, the proper depth of targeting still depends on the nature of the violation.

​

We also found that sanctions only target the tip of the iceberg when it comes to the regime's informal ties and general social capital. Less likely to be targeted are the vast networks of individuals that have been established over decades of illicit activities; if sanctions do target these networks, they focus only on small clusters and very few top players.

Networks like that of Assad’s regime, from a graph theory perspective, are resilient in structure, dynamic, and regenerative, highlighting the need for a constant revision of sanctions. Like any clandestine cell system, Syrian regime culprits can mitigate these penalties by devising novel ways to evade restrictions, like the use of cryptocurrencies, which are under consideration by the Central Bank of Syria,[38] and the continuous help of hackers like the Syrian Electronic Army.[39] The success of these evasion tactics implies that the current targeting styles not only make sanctions less efficient — more dangerously, they could make such networks antifragile, not only resisting and recovering from the stressor, but becoming stronger because of it.[40] 

Damaging the strong ties of trust and loyalty between entities in a network leads to the activation of “weak ties,” a key mechanism to absorb the shock.[41] In social network analysis, weak ties are the acquaintance relationships, used to enable collaboration and the diffusion of information. On a personal level, they can help you find a job.[42] But on a clandestine network level, they enable network cells to maintain operational ties with the larger network from which supplies and benefits are drawn; the weak ties allow a cell to reattach to the network when its strong ties have been targeted or isolated by law enforcement or rival cells.[43]

Another problem that weakens the effectiveness of sanctions is the lack of an established rewards program and incentive mechanisms for whistleblowers who directly provide first-hand testimony. Such rewards can come in the form of financial compensation or physical protection, including offering asylum. Syria suffers from a severe lack of freedom of expression, and when brave citizens are offered no incentive to come forward — especially as some risk their lives when they reveal what is happening in-country or leak classified information — the sanction programs ignore a crucial potential contribution that could massively improve their effectiveness.

Some key progress has been made in this area recently. The Bassam Barabandi Rewards for Justice Act[44] bibill was submitted to the US House of Representatives in February 2021. The act will help prosecute those who evade sanctions and violate human rights; if passed, it will be very useful in enhancing the effectiveness of US sanctions.

The current targeting style highlights that sanctions are often driven by behind-the-scenes arrangements. The published justifications for targeting an individual are in many cases not sufficient to convince the public; certain individuals who found their way onto the lists, like Karam al-Assad, were so insignificant that it was difficult to assess what type of behavior had earned them a spot. This has contributed to the growing perception that sanctions are driven solely by political moods and interests. Avoiding or delaying the listing of a person directly linked to violations in Syria could be seen as a political maneuver with the aim of winning over this individual as a potential facilitator in upcoming political settlements. An example of this is Samer Foz. According to Jihad Yaziji,[45] sanctions on Foz were initially put on hold as some parties believed that he was nominated to play a role in a political settlement. This changed later; he was sanctioned by the EU in January 2019,[46] and by the US in June 2019.[47]

Incompetence in Data and Processes

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Perhaps the most shocking discovery we made when analyzing the data on targeted individuals was the staggering number of errors uncovered during extraction from the official lists. Some mistakes raised numerous questions about the targeting strategies for this extremely important issue and just how seriously their implementation is being taken.

​

Some listed names are completely unknown to a wide range of Syrian pundits. It is also unclear how often these lists are maintained and updated; we found 14 listed people who have died, for instance. This could have been a deliberate decision, designed to freeze the assets of the deceased and block access by their heirs, but we were unable to find much information, leaving the matter unresolved.

Also, we found misspelled names that do not match with official records or published sources, like “Sua’amaia Saber Hamcho (Arabic: سعمية صابر حمشو),”[48] whose correct Arabic name is سمية (Sumayah). This is different from an individual intentionally misspelling their own name to avoid sanctions, or changing it altogether — like Wasim Badea al-Assad, now Wasim Shahrour, according to recent comments by Ayman Abdel Nour.[49]. Moreover, some familial connections were so utterly wrong that it made us skeptical of not only the fact-checking process, but the targeting approach altogether. An example is when Mohammad Hamcho was found listed as the brother-in-law of Maher al-Assad on one of the EU sanction lists.[50] Hamcho is widely known for serving as a front man for Maher al-Assad, but there is no known kinship relation between them.

 
Moreover, for individuals sanctioned by both the EU and US, the birthdates of several individuals do not match between the lists. For example, Dhu Al Himma Shalish’s date of birth is listed as 1946 on the EU list,[51] but as 1956 on the US list,[52] shedding light on the lack of coordination at the data level. The existence of these “data silos”[53] — where datasets are isolated rather than integrated and shared to be accessed by different groups — has a potentially severe impact on the effectiveness of sanctions and the decision-making around them.

The data strategies adopted by the EU and US should enable effective data integration and coordination. Bridging data silos at the targeting stage can reduce opportunity loss and increase the sanctions' effectiveness. However, while bridging seems an effective mechanism, a study published in 2020 by the global risk consultancy Control Risks[54] noticed a major trend whereby the “EU and US are growing apart on sanctions policy,” and predicted that the schism will increase to the point where the EU will seek more autonomy.

​

We also noticed some logical conflicts. One is that the sanctions do not seem to cascade automatically or follow any sort of hierarchy. For example, some sanctions targeted the entire Syrian army first, then later its 1st Corps. This defies rationality and suggests that some sanctions are probably redundant.

Finally, we found that the sanctions lists do not include all of the heads of the security apparatus, military intelligence, militia factions, etc. — individuals necessarily involved in oppressing civilians, given their seniority and notoriety. These individuals are very well known to the public. However, most ministers have been sanctioned, including cabinet ministers and ministers of state, even though they tend to play a marginal role in state management compared to the previous group. This finding raises immediate questions about the methodology and selection process for sanctions, which should be more comprehensive and target actual influencers.

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Ambiguity in Justifications

Although sanctions are usually supported by a justification statement highlighting why an entity was listed, most of these statements are somewhat abstract and do not provide sufficient detail for anyone interested in knowing more. This ambiguity can cause confusion; for example, Syrian Vice-President Farouk al-Shara'a was sanctioned for his involvement in “violence against the civilian population,” despite the fact that he has publicly denounced violence and was barred from public appearances for a long time because of it.[55] This is not to exonerate him from any wrongdoing, and there may be other reasons or evidence that led to his sanctioning, but we believe this information should be shared to prevent speculation.

Such ambiguity in justification has multiple impacts, including the growing belief among ordinary Syrians that sanctions are cherry-picked, biased, and reactive to public outrage in the West, rather than a means for accountability and democratic transition. Sanctions are viewed as a way for Western countries to avoid the embarrassment of complete inaction; this belief is reinforced when the tactic is not used in conjunction with other policy levers that might result in an actual change in behavior by the regime.

​

Another impact of vague justification statements is that they feed the simplistic belief by most observers that Western sanctions hurt only civilians, when in fact sanctions are like a sledgehammer, hurting the regime as well as the people. It is difficult to track any behavioral change without the particular details of the tactics used by businessmen to help the regime evade sanctions, and companies' complex ownership structures used by key regime figures to manage their foreign accounts. Syrian organizations, grassroots movements, and watchdog groups that use open-source intelligence tools also have trouble monitoring and tracking the impact opaquely-justified sanctions have on targeted entities.

Ambiguity about the sequence of criminal acts that led to an entity being sanctioned may give the regime a means to not only evade sanctions, but to mislead the listing process, putting selected low- or non-criminal individuals into the spotlight as blinds for the real perpetrators. This tactic also provides a tool for the regime to manage internal rivalries, using global sanctions as a means of blackmail and scapegoating. Moreover, sanctions aimed solely at "little fish" may unintentionally tip off "big fish," giving them time to change their illicit tactics. 

​

Finally, such ambiguity helps feed regime propaganda and attempts to deflect the attention of the Syrian people from the more relevant causes of their struggling economy (e.g., corruption, aid diversion, mismanagement, etc.).

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An Assessment of Sanction Impacts as a Tactic

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This section assesses sanction impacts in general and their effectiveness in achieving their intended goals. Efforts to answer this question are not new; some of the published studies on the feasibility of economic sanctions date back to 1925.[56]  Various research papers like J. Galtung,[57] D. Seekins,[58] and P. Wallensteen[59] concluded that economic sanctions are not overly effective in achieving the desired changes. G. Lopez[60]  concluded that, especially in authoritarian regimes, sanctions lead to suffering and economic hardships for citizens far more often than to any political change.
Relatively newer research uses more quantitative analysis and game theory. In a paper published in 2019,[61] Dursun Peksen modeled economic sanctions using a game-theoretic approach to simulate their effectiveness. He argued that sanctions’ success against dictatorships varies based on the type of targeted autocracy. 

Single-party and military regimes are less likely to surrender to foreign pressure, as they can effectively use various repressive approaches to tolerate the costs of the coercion. Sanctions against personalist[62] regimes are more likely to be effective, however, since there is less institutional capacity to support the leader. It is difficult to label the Syrian regime specifically as personalist, because it still has reasonably functional civil and military institutions.

George Tsebelis published an interesting paper in 1990,[63] which modeled six scenarios of sanctions driven by game theory concepts. He arrived at counter-intuitive conclusions, which he called the “Robinson Crusoe fallacy.” While acknowledging the shortcomings of applying game theory in policy analysis — given its tendency to be abstractive, the insufficiency of data points, the challenges of quantifying variables and establishing causality, etc. — the author introduced an approach that aligns nicely with policy analysis techniques.

​

The two main findings reported by Tsebelis are:

1. The six scenarios, driven by game-theoretic models, showed that, contrary to conventional wisdom that changing the incentives of one player will modify his behavior, in reality it modifies the behavior of his opponent. In other words:

   •  To decrease the frequency of violations, the sender country (applying the sanctions) must modify the payoffs/incentives. An example of payoffs is the economic cost of applying sanctions given that violations are committed.

   •  To decrease the frequency of sanctions, the target country (being sanctioned for violations) must modify their payoffs. An example of payoffs is the diplomatic costs of harmonious/strained relations between sender and target. 

2. Conventional analysis examines sanctions from the perspective of the target country. It ignores the fact that sanctions and violations are the outcome of two-player interaction, a game between rational players trying to promote their own goals, both capable of behavioral change, rather than “a simple decision against nature.” This ignorance of that fact is what Tsebelis calls his “Robinson Crusoe fallacy.” 

​

One main caveat of Tsebelis’ paper is that it uses a mixed payoffs/incentives model, making it difficult to attribute the change in one country’s behavior to the modification of a single action; rather, a collective change in actions/policies is needed to reach equilibrium. In the case of the Syrian regime, it appears Assad is doubling down on violations and sticking to his defiance, hoping that the US/EU will change their actions in the end (i.e., the cost of sanctions will no longer be in US/EU interests and the benefits of harmonious relations with the regime will become more feasible). 

This finding aligns with the argument made by Joshua Landis and Steven Simon,[64] who criticized the Trump administration's sanctions (specifically, the Caesar Act) targeting the construction, electricity, and oil sectors in Syria — making it impossible for even non-US aid organizations to contribute to the reconstruction of the country (specifically in the “small-scale infrastructural rehabilitation”).[65] They concluded that the assumption these sanctions will force the Syrian regime to change its incentives, where “Assad will freely accept the UN plan—which calls for fair elections, a new constitution, and credible, inclusive and non-sectarian governance,” is “disconnected from reality.”[66]

A more balanced policy paper, in terms of asking both senders and target countries, rather than just one or the other, to change their approaches was published by the Syria Justice and Accountability Centre (SJAC) in June 2020. It calls on both the US/EU and Syria to change their payoffs and incentives, especially during the COVID-19 crisis.[67] The paper recommended that the US/EU should:

• Inform exporters of essential medical equipment that humanitarian endeavors are exempted from sanctions

• Temporarily exempt dual-use products

• Ease the restrictions on remittance payments to Syria

• “Negotiate a relief mechanism modeled after the Swiss-Iran humanitarian channel”

​​

At the same time, the paper recommends that the Syrian regime reduce the impact of sanctions and enhance its relations with the West by freeing political detainees, allowing access to prisons, and sharing COVID-19 data with the World Health Organization.

​

We will take a simpler approach in assessing the effectiveness of sanctions, as we believe the empirical literature review cannot be relied upon due to various caveats like tiny sample size, time horizon issues, the inability to establish causality, and many others. Our approach is more qualitative and discusses effectiveness in terms of negative and positive impacts.

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Positive Impacts

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We grouped the positive impacts into four main points:

1. Sanctions coerce entities to change behavior and/or accept compromises. To understand the achievement levels of this goal, we studied the delisted entities. Foreign government entities included the Turkish ministries of Defense and Natural Resources (and their ministers, Hulusi Akar and Fatih Donmez) that were both sanctioned and then delisted in October 2019 under EO 13894 for “Contributing to the Situation in Syria.”[68]  Private-sector entities Blue Marine Shipping Agency and Skirron Holding AG (both in Switzerland) were sanctioned under EO 13582 for conducting economic transactions with the regime, but were then delisted three days later.[69] These two groups changed their behavior after the sanctions were imposed, and the change in behavior prompted the sanctions to be lifted. Coercing sanctioned entities into behavioral changes in this case is better than the option of no sanctions at all. It is important to note that the success in reaching desired change partly depends on where the sanctioned entities are located and where they do most of their business. For example, the entities in Switzerland likely did not want to jeopardize their ties in EU and US markets, so they complied. An actor with limited involvement in these areas may not be scared off by sanctions, however. 
    

2. Sanctions have given the Assad regime and its backers (Iran and Russia) one more reason to seek a political settlement to the conflict. This cannot be overlooked. The regime does not want to remain broke forever, while Russia and Iran want both an exit from the Syrian quagmire and an opportunity to benefit from the political settlement (military bases, reconstruction, financial benefits, etc.). Unilateral economic sanctions have never, on their own, led to the collapse of a regime. Yet in some cases they can at least cripple the targeted individuals and entities and make it difficult for them to get away with atrocities. 
    

3. Sanctions are a deterrence tool, sending explicit signals to individuals and entities involved with sanctioned targets that they are being watched and could be next, if they normalize their relations with targets or haven’t disowned any covert or overt activities. For example, foreign companies’ involvement in reconstruction activities on expropriated (regime-seized) land in Damascus is virtually non-existent primarily due to US/EU sanctions. While this tool definitely works, as reflected in the example above, it often doesn’t receive enough credit because we can’t see its impact in action (i.e., we don’t know when a company decides to not take action in Syria; we only know when they take action). Since it has recently become easier to implement secondary sanctions under the Caesar Act, the effectiveness of this objective can be better utilized.
    

4. Sanctions send a message to other countries that mass killings and torture cannot be carried out with absolute impunity. Although Assad’s regime has raised the bar to a level that encourages other dictatorships to commit what would once have been considered unimaginable without being forcefully stopped by Western powers, sanctions send a message to other dictators that the West may not completely overlook their actions.

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Negative Impacts

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When assessing the negative impacts of sanctions, it is important to distinguish between negative impacts caused by sanctions, and those that simply correlate with them. For example, the multiple sanction regimes have undoubtedly contributed to Syria's economic distress. However, despite the regime's messaging, the sanctions are not the only reason for that distress; the Caesar Act came into effect after years of institutional corruption, a war economy, aid diversion, and mismanagement, all exacerbated by the ramifications of the COVID-19 pandemic and the banking crisis in Lebanon. Some would argue that even if the regime wanted to import some goods targeted by the Caesar Act, it is not clear if it has the funds to do so. How easy would it be for the regime to secure a loan from foreign banks even if there were no sanctions, given its low credit profile?

We grouped the negative impacts into five main points:

1. On the humanitarian front, the sanctions have had a negative impact on Syrian non-governmental organizations (NGOs) operating within and outside Syrian borders. In a report published by IMPACT Civil Society Research and Development,[70] various Syrian organizations operating in France, the UK, Germany, Turkey, and Lebanon shared the challenges they face. Many have had their bank accounts closed, were blocked from opening new ones, and were not allowed to send or receive wire transfers. Some were forced to transact only with EU-based banks. These measures usually included no stated justification and were attributed to over-compliance; in a few cases, stated justifications ranged from a Syrian being a member of the NGO’s board of directors to a vague excuse that the situation in Syria is unstable.
    

2. Sanctions have caused huge problems for Syrian civilians living abroad. Over-compliance tracked them in various countries around the world, closed their accounts, and prohibited them from opening new ones, often without explanation, all leading to a chilling effect whereby no one wanted to transact with them, for no apparent good reason.[71]
    

3. There is near-total academic consensus that, regardless of type, economic sanctions have a negative impact on national economies. This is especially true in countries where dictatorship is mixed with monopoly, crony capitalism, and a strongly skewed distribution of wealth. In Syria, individuals and entities with greater access to resources and power are more able to endure the sanctions, while small- and medium-sized enterprises, especially those not involved with the regime, are more likely to fail as access to resources becomes exclusive. 
    

4. Sanctions have blocked rehabilitative services in areas not controlled by the regime. In rebel-held territory in northwestern Syria, besides making it almost impossible for international NGOs to contribute to “small-scale infrastructural rehabilitation,”[72] the Caesar Act recently blocked technology resources there, including Google Workspace (formerly Google Business Suite), a suite of applications used by many Syrian civil society organizations (CSOs) and NGOs.[73] Western technology bans on Syria are not new, but it has never been this extensive. It includes many online services in which technology is either at the core (e.g., Oracle Java and Google Chrome),[74] or operates as a business enabler (e.g., freelance job sites Freelancer and Upwork).[75] The list is constantly growing to include popular platforms like Netflix and Zoom as well,[76] but the surprising fact about Google Workspace is that the Internet cables in areas outside regime control are connected to networks in Turkey or Iraq, not Syria.[77]

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Philosophies of the Engaged Parties

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The final assessment of this study will try to understand the sanctions from the main target’s point of view as well as from that of the Western countries imposing them. In March 2021, 14 Syrian dissident organizations published a letter[78] asking Bashar al-Assad to suspend the US/EU sanctions himself by fulfilling certain criteria of the Caesar Act, like releasing political prisoners and establishing a structured process for accountability. Like every other attempt over the years of conflict, this was essentially ignored by Assad.

 
We believe Assad’s choice not to concede to sanctions is rational, as the negative impacts of a political settlement are greater for him than those imposed by sanctions. Open elections would mark the beginning of the end of the regime, as it is not popular with the citizenry. A survey conducted in Damascus in late 2020 by the Operations and Policy Center showed that nearly two-thirds of respondents wish to leave the country (63.5%).[79] Even people in Assad’s most cared-for areas are sick of living under his rule.

Without the protection of his office, Assad would likely be under threat all the time, whether in Syria or abroad. Justice is much more likely to be served on the weak; he might face the same fate as Adib Shishakli, a former Syrian dictator who was assassinated on September 27, 1964 in Brazil by Nawaf Ghazaleh, a Syrian who sought revenge for the death of his parents, killed in Shishakli’s military operation against Jabal Druze. Alternatively, he could be brought to justice despite all the assurances, in a similar scenario to Augusto Pinochet, the former Chilean military dictator, who was indicted and arrested in the UK under the principle of universal jurisdiction.[80]

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As for Western politicians, we believe they know by now that sanctions alone are not enough to compel the Assad regime to accept a fair settlement to the conflict. However, they also know that incentivizing Assad’s backers and exerting enough additional pressure on them to trigger a behavioral response is not cheap. We must therefore conclude that, above all, sanctions are to Western politicians little more than a fig leaf to cover their lack of genuine interest in finding a solution to the Syrian crisis in the face of domestic pressure to end the misery of the Syrian people within and outside the country, and a reflection of their political weakness in Syria.

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Policy Recommendations

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The current model of sanctions is suboptimal, with a high likelihood that sanction targets can use evasive strategies to avoid any actual harm. We believe this would still hold even when, as recommended by Zaki Mehchy and Rim Turkmani,[81] easing/lifting sanctions is applied on meso-level actors: small and medium-sized independent business and CSOs that would receive targeted support to lessen the suffering of people.

We recommend three main changes to US/EU sanctions policy, keeping in mind that such changes need to be, as much as possible, made as a whole and not in parts:

​

1. First, scrap all forms of country-based and sector-based sanctions, especially on financial transactions, as their harm outweighs the benefit, even for ordinary Syrians in the diaspora and opposition-held areas. This should be done in exchange for gains, such as releasing prisoners. Instead, expand the use of travel bans and asset freezes.
    

2. Implement a more active whole-of-Syria policy by threatening more sticks and offering more carrots than in the current framework. Avoid making sanctions the primary policy tool, as this tactic is unlikely to result in behavioral change. 

   • Carrots: Provide incentives for Assad’s allies to pressure him into compromising or disposing of him, by demonstrating that he remains the primary impediment to their own interests. Incentives could take the form of reconstruction and concessionary loan promises redeemable upon Assad’s removal from power.

   • Sticks: Expedite and facilitate legal action taken against regime officials and its enablers abroad in Western and international courts.
      

3. Improve the effectiveness of sanctions:

   • Use secondary sanctions more actively, especially on less-entrenched individuals where a change in behavior is more likely.

   • Go beyond the tip of the iceberg; target the deep networks of the regime. Sanction all heads of security apparatus, military intelligence, militia factions, and businessmen affiliated with the regime.

   •  Establish a reward program to incentivize Syrians, especially those living in-country, to speak out and uncover individuals involved in the regime’s crimes. Rewards can be either financial or the offer of asylum.

   •  Involve Syrian organizations, grassroots movements, and watchdog groups in collecting evidence and mapping the power structure of the Syrian regime, in order to minimize and correct errors in the current sanction lists.

   •  Bridge the data silos and increase coordination between the US and EU to enhance sanction impacts.

   •  Improve transparency and communication with the public to enhance the impact of sanctions: Why exactly are some people listed? Why are they delisted? Why was the Caesar Act applied to only four individuals?

   • Adopt an agile re-evaluation and review process for imposed sanctions, in order to quickly weigh their cost-effectiveness and make corresponding adjustments. This will minimize the effects of misapplied sanctions that lead to unintended consequences. This aligns to some extent with Mehchy and Turkmani’s recommendation of establishing a monitoring system for sanctions.[82]

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Acknowledgement

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The authors would like to thank Joseph Daher and Zaki Mehchy for their valuable comments and suggestions to this paper. We also thank Ammar al-Nakeeb for his assistance in analyzing the data and assessing the impacts of sanctions on humanitarian aid.

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Sources

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1. ​George Popp, “Kinetic and Non-Kinetic Tactics of Competing Powers Over the Coming Decade,” PDF, NSI, Inc., September 2019, https://nsiteam.com/social/wp-content/uploads/2019/09/Future-of-Global-Competition-and-Conflict-ViTTa-Q2-Report_final.pdf. 
    

2. Syrian Network for Human Rights, “Do I Support the US Sanctions on My Country?” Karam Shaar website, July 27, 2020, https://www.karamshaar.com/do-i-support-the-us-sanctions.
    

3.   Such brief periods included collaboration with the regime, for example, at the beginning of the war in Lebanon and in the Second Gulf War with Syria’s support for US intervention in 1991.
    

4.   “Syria Sanctions,” United States Department of State, accessed May 14, 2021, https://www.state.gov/syria-sanctions/.
    

5.   “Executive Order 13224 (September 23, 2001),” U.S. Department of State, March 16, 2021, https://www.state.gov/executive-order-13224/.     
    

6.   “Specially Designated Nationals and Blocked Persons List (SDN) Human Readable Lists,” U.S. Treasury Department, accessed May 14, 2021, https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists.
    

7.   “Suspected Al-Qaeda Financier Detained,” CBCnews (CBC/Radio Canada, October 15, 2004), https://www.cbc.ca/amp/1.499137.
    

8.   “Additional Designation Of Six Individuals Pursuant To Executive Order 13315,” Federal Register, 2007, https://www.federalregister.gov/documents/2007/12/17/E7-24342/additional-designation-of-six-individuals-pursuant-to-executive-order-13315.
    

9.   “Syrian Company, Nationals Designated by Treasury for Support to Former Saddam Hussein Regime,” U.S. Treasury Department, June 9, 2005, https://www.treasury.gov/press-center/press-releases/Pages/js2487.aspx.
    

10.   “Executive Order 13338—Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria,” PDF, U.S. Treasury Department, May 13, 2004, https://home.treasury.gov/system/files/126/13338.pdf.
     

11.   108th U.S. Congress, “Syria Accountability and Lebanese Sovereignty Restoration Act of 2003,” United States Congress, December 12, 2003, https://www.congress.gov/108/plaws/publ175/PLAW-108publ175.pdf.
     

12.   “Executive Order 13382, ‘Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters;’ The Weapons of Mass Destruction Trade Control Regulations (Part 539 Of Title 31, C.F.R); and The Highly Enriched Uranium (HEU) Agreement Assets Control Regulations (Part 540 Of Title 31, C.F.R),” U.S. Treasury Department, 2005, https://home.treasury.gov/system/files/126/wmd.pdf.
     

13.   “Treasury Sanctions State-Owned Syrian Financial Institutions and Syria’s Largest Mobile Phone Operator,” U.S. Treasury Department, August 10, 2011, https://www.treasury.gov/press-center/press-releases/Pages/tg1273.aspx.
     

14.   George W. Bush, “Executive Order 13399: Blocking Property of Additional Persons in Connection with The National Emergency with Respect to Syria,” U.S. Treasury Department, 2006, https://home.treasury.gov/system/files/126/13399.pdf; George W. Bush, Administration of George W. Bush, 2007, PDF (repr., Washington, D.C.: U.S. Government Publishing Office, 2007), 1035-1037, https://www.govinfo.gov/content/pkg/WCPD-2007-08-06/pdf/WCPD-2007-08-06-Pg1035-2.pdf.
     

15.   U. S. Congress, House, Caesar Syria Civilian Protection Act Of 2019, HR 31, 116th Congress, 1st sess., reported to Senate June 3, 2019, https://www.congress.gov/bill/116th-congress/house-bill/31/text.
     

16.   Karam Shaar and William Christou, “US Sanctions Hurt Syrian Civilians: They Need to Be Worth It,” Middle East Institute, 2020, https://www.mei.edu/publications/us-sanctions-hurt-syrian-civilians-they-need-be-worth-it.
     

17.   “Hindawi affair,” Wikipedia (Wikimedia Foundation, April 3, 2021), https://en.wikipedia.org/wiki/Hindawi_affair.
     

18.   Gary Clyde Hufbauer et al. “US v. Syria (1986-: Terrorism),” The Peterson Institute for International Economics (PIIE), https://www.piie.com/commentary/speeches-papers/case-86-1. 
     

19.   A publicly owned international financial institution whose shareholders are EU member states. “Homepage | European Investment Bank,” EIB.Org, 2021, https://www.eib.org/en/.
     

20.   Laurence Norman, “EU Set to Broaden Syria Sanctions,” The Wall Street Journal, 2011, https://www.wsj.com/articles/SB10001424052970204224604577030251441246074.
     

21.   U.S. Energy Information Administration, “Over 90% of Syrian Crude Oil Exports Go to European Countries,” EIA, 2021, https://www.eia.gov/todayinenergy/detail.php?id=3110.
     

22.   Clara Portela, The EU’S Sanctions Against Syria: Conflict Management by Other Means, PDF (repr., Egmont – Royal Institute for International Relations, September 2012), https://core.ac.uk/download/pdf/10593778.pdf.
     

23.   Rim Turkmani and Mustafa Haid, “The role of the EU in the Syrian conflict,” Security in Transition, London School of Economics (LSE), 2016, https://brussels.fes.de/fileadmin/public/editorfiles/events/Maerz_2016/FES_LSE_Syria_Turkmani_Haid_2016_02_23.pdf 
     

24.   The Telegraph, “US President Barack Obama in 'red line' warning to Syria over chemical weapons,” August 21, 2012, video, 1:36, https://youtu.be/avQKLRGRhPU; “Remarks by the President to the White House Press Corps,” Barack Obama White House Office of the Press Secretary, August 20, 2012, https://obamawhitehouse.archives.gov/the-press-office/2012/08/20/remarks-president-white-house-press-corps.
     

25.   “Syria–The Winds,” Encyclopedia Britannica, accessed May 14, 2021, https://www.britannica.com/place/Syria/The-winds#ref29952
     

26.   U.S. Central Intelligence Agency, “World Fact Book: Syria (Section ‘People and Society’),” CIA, accessed May 14, 2021, https://www.cia.gov/the-world-factbook/countries/syria/#people-and-society.
     

27.   Reuters Staff, “Syria’s Alawites, A Secretive and Persecuted Sect,” U.S., 2012, https://www.reuters.com/article/us-syria-alawites-sect-idUSTRE80U1HK20120131.
     

28.   Ibid.
     

29.   Ibid.
     

30.   “Syria Designations; Update to the SDN and Foreign Sanctions Evaders Lists,” U.S. Department of the Treasury, December 17, 2014, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20141217.
     

31.   “Treasury Sanctions Networks Providing Support to the Government of Syria, Including for Facilitating Syrian Government Oil Purchases From ISIL,” U.S. Department of the Treasury, November 25, 2015, https://www.treasury.gov/press-center/press-releases/pages/jl0287.aspx.
     

32.   Maria Tsvetkova and Ellen Francis, “Beirut Blast Chemicals Possibly Linked to Syrian Businessmen: Report, Company Filings,” Reuters, January 17, 2021, https://www.reuters.com/article/lebanon-crisis-blast-idINKBN29M0A7.
     

33.   Office of Foreign Assets Control, “Issuance of Syria Frequently Asked Questions; Syria Designations; Syria-Related Designations and Designation Update,” U.S. Department of the Treasury, December 22, 2020, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201222.
     

34.   “Mqablh Khash | Njl Wzyr Aldfa’e Alswry Alasbq Fras Tlas – Aljz’ Althany [Private Interview | Son of Former Syrian Defense Minister Firas Tlass - Part Two],” Arabic language video without subtitles, 37:52 (19:00), AlHadath Event, March 25, 2021, https://youtu.be/Ru2k4Mfru3c?t=1140.
     

35.   “The National Defense Authorization Act 2020 - Conference Report,” U.S. Department of the Treasury, December 9, 2019, https://home.treasury.gov/system/files/126/ndaa_fy2020.pdf.
     

36. ““Syria Designations; Syria-Related Designations and Designation Removal,” U.S. Department of the Treasury, July 29, 2020, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20200729.
     

37.   “Syrian Businessman Wasim Qattan Comments on His Name Being Included in European Sanctions,” The Syrian Observer, February 19, 2020, https://syrianobserver.com/news/56156/syrian-businessman-wasim-qattan-comments-on-his-name-being-included-in-european-sanctions.html.
     

38.   Adnan Abdul Razzaq, “Alnzam Alswry Y’etzm Trh ‘Emlh Rqmyh Wawraq Nqdyh Kbyrh [The Syrian Regime Intends to Put up a Digital Currency and Large Banknotes],” The New Arab, January 29, 2021, http://bit.ly/TheSyrianregimeintendstoputupadigitalcurrencyandlargebanknotes.
     

39.   “Syrian Electronic Army,” Wikipedia (Wikimedia Foundation, April 3, 2021), https://en.wikipedia.org/wiki/Syrian_Electronic_Army.
     

40.   ““Antifragility,” Wikipedia (Wikimedia Foundation, May 6, 2021), https://en.wikipedia.org/wiki/Antifragility.
     

41.    Mark S. Granovetter, “The Strength of Weak Ties,” American Journal of Sociology 78, no. 6 (May 1973): pp. 1360-1380, https://doi.org/10.1086/225469.
     

42.   Andy Molinsky, Jane Heifetz, and Dorie Clark, “‘A Friend of a Friend’ Is No Longer the Best Way to Find a Job,” Harvard Business Review, November 2, 2017, https://hbr.org/2017/06/a-friend-of-a-friend-is-no-longer-the-best-way-to-find-a-job.
     

43.   José A. Rodríguez, “The March 11th Terrorist Network: In Its Weakness Lies Its Strength,” CiteSeerX (University of Barcelona Department of Sociology and Analysis of Organizations, December 2005), http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.98.4408.
     

44.   U.S. Congress, House, Bassam Barabandi Rewards for Justice Act, HR 1036, 117th Congress, 1st sess., introduced in House February 11, 2021, https://www.congress.gov/bill/117th-congress/house-bill/1036/text; “Congress Inches Closer to Approval of Bassam Barabandi Act,” The Syrian Observer, February 19, 2021, https://syrianobserver.com/features/63981/congress-inches-closer-to-approval-of-bassam-barabandi-act.html.
     

45.   Syria Justice and Accountability Centre, “Neqash Hey Hewl Al’eqewbat Aledwelyh ‘Ela Sewreya Wekyefyh T’ezeyz Mekafhh Kewrewna Fey Zel Al’eqewbat [A Lively Discussion on International Sanctions on Syria and How to Strengthen the Fight against Coronavirus under Sanctions],” Facebook Live, video, 45:17 (30:10), April 21, 2020, https://www.facebook.com/watch/?v=319877378974401.
     

46.   Council of the European Union, “Council Implementing Decision (CFSP) 2019/87 of 21 January 2019 Implementing Decision 2013/255/CFSP Concerning Restrictive Measures against Syria,” PDF, EUR-Lex Access to European Law (Official Journal of the European Union, January 21, 2019), https://eur-lex.europa.eu/legal-content/en/TXT/PDF/?uri=CELEX:32019D0087&from=EN.
     

47. ““Treasury Designates Syrian Oligarch Samer Foz and His Luxury Reconstruction Business Empire,” U.S. Department of the Treasury, June 11, 2019, https://home.treasury.gov/news/press-releases/sm704.

     

48. “Syria-Related Designations; Syria Designations and Designations Updates; Iran-Related Designation Update; Counter Terrorism Designation Update,” U.S. Department of the Treasury, June 17, 2020, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20200617.

     

49. AlHadath event, “Nesherh 15 Gheryenyetsh: Aferad Men ‘Ea’elh Alased Yetkhelwen ‘En Asem Al’ea’elh [Greenwich Newsletter | Members of the Al-Assad Family Give up the Family Name],” March 18, 2021, video, 50:48 (36:50), https://youtu.be/iRKtZsZxXKU?t=2211.

     

50. Council of the European Union, “Council Implementing Decision 2011/302/CFSP of 23 May 2011 Implementing Decision 2011/273/CFSP Concerning Restrictive Measures against Syria,” PDF, Lex Access to European Union law (Official Journal of the European Union, May 24, 2011), https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32011D0302.

     

51. Council of the European Union, “Council Implementing Regulation (EU) 2020/716 of 28 May 2020 Implementing Regulation (EU) No 36/2012 Concerning Restrictive Measures in View of the Situation in Syria ,” PDF, EUR-Lex Access to European Law (Official Journal of the European Union, May 28, 2020), https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32020R0716&from=EN.

     

52. “Syria Designations: Specially Designated Nationals Update,” U.S. Department of the Treasury, March 30, 2021, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20120330.

     

53. “Information Silo,” Wikipedia (Wikimedia Foundation, April 23, 2021), https://en.wikipedia.org/wiki/Information_silo.

     

54. Control Risks Group, “Navigating the Global Sanctions Landscape in 2020: Diverging Paths, Increasing Risks,” PDF, GlobeNewswire, October 2019, https://ml.globenewswire.com/Resource/Download/c0114454-5fbc-4870-ae83-936b64328d83.

     

55. Associated Press, “Syrian Vice-President Says Neither Side Can Win War,” CBCnews (CBC/Radio Canada, December 18, 2012), https://www.cbc.ca/news/world/syrian-vice-president-says-neither-side-can-win-war-1.1178611.

     

56. “74 U. Pa. L. Rev. 155 (1925-1926) Economic Sanctions and International Security,” HeinOnline, March 8, 2021, https://heinonline.org/HOL/LandingPage?handle=hein.journals%2Fpnlr74&div=19&id=&page=.

     

57. 1.      Galtung, J. (1967). On the Effects of International Economic Sanctions: With Examples from the Case of Rhodesia. World Politics, 19(3), 378-416. doi:10.2307/2009785

     

58. 1.      Seekins, D. M. (2005). Burma and U.S. Sanctions: Punishing an Authoritarian Regime. Asian Survey, 45(3), 437-452. doi:10.1525/as.2005.45.3.437

     

59. Wallensteen, P., & Sollenberg, M. (2001). Armed Conflict, 1989-2000. Journal of Peace Research, 38(5), 629-644. doi:10.1177/0022343301038005008

     

60. Lopez, G. A. (1999). More Ethical than Not: Sanctions as Surgical Tools: Response to “A Peaceful, Silent, Deadly Remedy”. Ethics & International Affairs, 13(1), 143-148. doi:10.1111/j.1747- 7093.1999.tb00331.x

     

61. Dursun Peksen, “Autocracies and Economic Sanctions: The Divergent Impact of Authoritarian Regime Type on Sanctions Success,” Taylor & Francis (from Defence and Peace Economics, 30:3, 253-268, DOI: 10.1080/10242694.2017.1368258, August 28, 2017), https://www.tandfonline.com/doi/abs/10.1080/10242694.2017.1368258.

     

62. Torrey Taussig, “The Rise of Personalist Rule,” Brookings (The Brookings Institution, March 23, 2017), https://www.brookings.edu/blog/order-from-chaos/2017/03/23/the-rise-of-personalist-rule/.

     

63. George Tsebelis, “Are Sanctions Effective? A Game-Theoretic Analysis,” Journal of Conflict Resolution 34, no. 1 (March 1990): pp. 3-28, DOI: 10.1177/0022002790034001001, PDF accessed at https://sites.lsa.umich.edu/tsebelis/wp-content/uploads/sites/246/2015/03/are_sanctions_effective_1990_jcr.pdf.

     

64. Joshua Landis and Steven Simon, “The Pointless Cruelty of Trump’s New Syria Sanctions,” Foreign Affairs, August 17, 2020, https://www.foreignaffairs.com/articles/syria/2020-08-17/pointless-cruelty-trumps-new-syria-sanctions.

     

65. Basma Alloush and Alex Simon, “Will More Syria Sanctions Hurt the Very Civilians They Aim to Protect?,” War on the Rocks (Texas National Security Review, June 10, 2020), https://warontherocks.com/2020/06/will-more-syria-sanctions-hurt-the-very-civilians-they-aim-to-protect/.

     

66. “The Pointless Cruelty of Trump’s New Syria Sanctions.”

     

67. “Sanctions, the Caesar Act, and COVID-19 in Syria: Policy Analysis and Recommendations,” PDF, SyriaAccountability.org (Syria Justice and Accountability Centre, June 16, 2020), https://syriaaccountability.org/wp-content/uploads/Sanctions-the-Caesar-Act-and-COVID_0617.pdf.

     

68. Donald J. Trump, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria,” Federal Register, October 17, 2019, https://www.federalregister.gov/documents/2019/10/17/2019-22849/blocking-property-and-suspending-entry-of-certain-persons-contributing-to-the-situation-in-syria; “Syria-Related Designations Removals: Specially Designated Nationals List Update,” U.S. Department of the Treasury, October 23, 2019, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20191023.

     

69. “Notice of OFAC Sanctions Actions,” Federal Register (Office of Foreign Assets Control, U.S. Treasury Department, March 20, 2020), https://www.federalregister.gov/documents/2020/03/20/2020-05931/notice-of-ofac-sanctions-actions; ““Syria-Related Designation; Syria Designations Removals; Global Magnitsky Designation Removal; Foreign Sanctions Evaders Determination Removal: Specially Designated Nationals List Update,” U.S. Treasury Department, March 17, 2020, https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20200317.

     

70. Joseph Daher, “Invisible Sanctions: How Over-Compliance Limits Humanitarian Work on Syria,” ed. Erica Moret, PDF, IMPACT-Civil Society Research and Development, 2020, https://impact-csrd.org/reports/Invisible_Sanctions_IMPACT_EN.pdf.

     

71. “Invisible Sanctions.” This IMPACT report highlighted the case of one Syrian in Belgium whose account was closed. Also, we know cases where this was applied beyond Europe, e.g., in Malaysia (local and int’l banks) and Saudi Arabia (int’l banks). Also, the report used “the chilling effect” in this context to denote the tendency of no one’s, individuals and companies, willingness to deal with everything close to Syria.

     

72. “Will More Syria Sanctions Hurt the Very Civilians They Aim to Protect?”

     

73. M. Jihad Masri, “Yesterday Google Business Services in Syria Stopped,” Facebook, April 1, 2021, https://www.facebook.com/mahmoudjihadmasri/posts/10165252281790694.

     

74. Jessica Dheere, “Google Blocks Chrome Browser Use in Syria, Iran,” MediaShift, October 13, 2008, http://mediashift.org/2008/10/google-blocks-chrome-browser-use-in-syria-iran287/.

     

75. Freelancer Support, “Restrictions in Some Countries,” Freelancer.com, accessed April 15, 2021, https://www.freelancer.com/support/freelancer/General/restrictions-in-some-countries.

     

76. Damascus (AFP), “In Pandemic Year, Syrians Blocked from Zoom, Netflix,” France 24, March 19, 2021, https://www.france24.com/en/live-news/20210319-in-pandemic-year-syrians-blocked-from-zoom-netflix.

     

77. “Yesterday Google Business Services in Syria Stopped.”

     

78. ““Beshar Alased: Qem Benha’ Beramej Al’eqewbat Alesweryh [Bashar Al-Assad: End Syria Sanctions Programmes!],” Syrian Center for Media and Freedom of Expression, accessed April 15, 2021, https://scm.bz/en/scm-statements/bashar-al-assad-end-syria-sanctions-programmes#.

     

79. Sultan Jalaby, “Attitudes Toward Emigration in the Syrian Capital of Damascus: A Survey in Three Neighborhoods,” Operations and Policy Center, accessed June 3, 2021, https://opc.center/attitudes-toward-emigration-in-the-syrian-capital-of-damascus-a-survey-in-three-neighborhoods/.

     

80. “The Pinochet Precedent: How Victims Can Pursue Human Rights Criminals Abroad,” Human Rights Watch, November 16, 2020, https://www.hrw.org/report/1998/11/01/pinochet-precedent/how-victims-can-pursue-human-rights-criminals-abroad.

     

81. Zaki Mehchy and Rim Turkmani, “Understanding the Impact of Sanctions on the Political Dynamics in Syria” The London School of Economics and Political Science, January, 2021, http://eprints.lse.ac.uk/108412/1/CRP_understanding_impact_of_sanctions_on_political_dynamics_syria.pdf

     

82. Zaki Mehchy and Rim Turkmani, “Understanding the Impact of Sanctions on the Political Dynamics in Syria” The London School of Economics and Political Science, January, 2021, http://eprints.lse.ac.uk/108412/1/CRP_understanding_impact_of_sanctions_on_political_dynamics_syria.pdf