In 2024, the Biden administration imposed eight rounds of sanctions on 17 extremist West Bank settlers and leaders of organizations that had played a particularly egregious role in fomenting violence against Palestinians. The administration also imposed sanctions on nine entities, all of which have been deeply involved in the building and expansion of settlements in varying ways, and six notoriously extremist settler outposts.
Implemented on Feb. 1, 2024, the sanctions were the U.S. government’s response to a notable and concerning rise in settler violence that began in late 2023, following the Oct. 7, 2023, Hamas-led attacks. Many settlers and the organizations that provide them with financial support have direct connections to the U.S. Some in the Biden administration believed that sanctions might also allay criticism of the White House’s response to Israel’s military offensive in Gaza.
The sanctions worked by prohibiting targeted persons and entities from engaging in transactions with U.S. persons or in U.S. dollars. In many cases, the Israeli banks closed the sanctioned person or entity’s bank accounts and canceled their credit cards to avoid inadvertently violating the sanctions. Throughout 2024, the response from the Israeli government and its allies was to express displeasure and, in some cases, seek ways to help affected settlers evade the impact of the sanctions.
Among the sanctioned entities was Amana, a large and profitable construction company that has played a critical role in building many West Bank settlements since the late 1970s. Amana also supports two key settler organizations: Hashomer Yosh, a group of far-right activists who receive government funding to expand settler agricultural projects, including the expansion of illegal outposts and involving violent clashes with Palestinian farmers; and Lehava, a far-right, violent, Jewish supremacist organization that incites and organizes settler-led violence against Palestinians in the West Bank. Hashomer Yosh, which is largely funded by the Israeli government, has been linked to notorious violent incidents across the West Bank since its founding in 2013. In 2024, for example, residents of Meitarim Farm, a settler outpost, violently attacked and ethnically cleansed the nearby Palestinian Bedouin village of Khirbet Zanuta, which has since ceased to exist. Lehava has been connected to violence against Palestinians across the West Bank; its founder, Bentzi Gopstein, is a disciple of the late Rabbi Meir Kahane, a notorious racist who espoused ethnic cleansing of Palestinians. The sanctions also targeted Gopstein.
The sanctions did not, obviously, end Israel’s occupation of the West Bank, nor did they necessarily reduce individual acts of violence. But that was not their purpose, which is something that most people do not understand. Sanctions are not the sole means of altering behavior or policy. They are one of several tools that together can achieve a policy objective — such as forcing the Israeli government to rein in extremist settlers and stop expanding settlements. Sanctions meet their goal not when they change behavior but when they disrupt it. Ideally, that disruption happens in the context of a diplomatic or negotiation process that then can push the now-disrupted person or entity to a more permanent change in behavior.
In the case of the sanctions levied at key figures in the settler movement, the question is whether sanctions worked as their designers intended. Some said the sanctions were just symbolic and had minimal impact. Others said that their impact was undermined from within the U.S. government. Can both things be true? And what does the experience teach us about how sanctions work or fail in other contexts?
Let’s start with the immediate impact of the sanctions in Israel and the occupied West Bank when they were implemented. Based on published interviews with sanctioned individuals such as Reut Ben Haim and Elisha Yered, who were targeted for their role in disrupting aid convoys bound for Gaza and extreme violence in the West Bank, respectively, Israeli banks immediately closed their accounts and canceled their credit card access. This is called “de-risking”; foreign banks often cancel the accounts and credit cards of anyone on the U.S. sanctions list to avoid mistakenly processing a potentially risky transaction that involves U.S. dollars. This means that violent settlers cannot raise funds or carry out transactions in U.S. dollars, which has an impact on their financing networks. For example, the sanctions directly targeted several entities engaged in crowdfunding campaigns on behalf of sanctioned settlers. The fundraising platforms were forced to carry out due diligence and identify how they might have been helping extremist settlers raise money. Fundraising via crowdsourcing platforms was also the subject of two “alerts” by the Financial Crimes Enforcement Network (FinCEN). FinCEN is the U.S. government’s “financial intelligence unit,” the U.S. agency responsible for combating money laundering. Nearly every government around the world has an equivalent. Periodically, FinCEN issues alerts or advisories to all banks and financial institutions registered in the United States to highlight specific risks that are of significant interest to the agency and request reports of any potentially suspicious transactions that resemble the identified risks.
In Israel, political reaction to the sanctions showed that they had captured the attention of the settler leadership. This was particularly apparent when the effect of the sanctions expanded from a small number of individuals to multimillion-dollar organizations with thousands of members. Over the summer of 2024, Yisrael Ganz, chair of the Yesha Council, the umbrella organization for municipal councils of West Bank settlements, held a series of meetings with the Israeli government to complain that Prime Minister Benjamin Netanyahu and his ministers were not making sufficient efforts to defend them. Ganz wrote to the state comptroller about the sanctions, accusing the government of unjustly “criminalizing” people whom he described as law-abiding citizens. To the JNS (Jewish News Syndicate), a pro-settler English-language media platform, Ganz said: “The sanctions are a danger to the sovereignty of the State of Israel.” He added: “This is a slippery slope, and the Israeli government is not doing enough in this regard to protect its sovereignty.”
Based on reporting throughout 2024, it seems that the Netanyahu government did not expect the sanctions and was not prepared. They had no apparent course of action planned and did not seem to know how to respond. At one point, a bill was introduced in the Knesset, Israel’s parliament, that would have prohibited the Bank of Israel and other institutions from complying with U.S. sanctions. This shows that the sanctions were having an impact and that the targets believed the Netanyahu government’s response to the sanctions was insufficient.
The Israeli government did implement some changes in how it responded to settler violence, which was one of the U.S. government’s core policy objectives. In August 2024, for example, the Israeli government arrested four settlers who attacked the West Bank Palestinian village of Hit. Reuters reported that the attack “drew unusual condemnation from Israeli leaders, including Prime Minister Benjamin Netanyahu, who promised a swift investigation.” It is always challenging to present a single causal connection between a particular response by a government and sanctions, but given that settlers were widely perceived as operating in an environment of impunity, actions such as this were notable.
The European Union and the governments of several other countries, including the United Kingdom, Canada, Australia and Japan, imposed similar sanctions. These remain in place and will continue to pose challenges to targeted individuals and entities as they seek to use the financial system, given that many banks and companies use screening tools that incorporate sanctions lists from across the globe. These tools rely on software providers who look for “negative news” on specific individuals and similar alerts on a broader topic, such as the July 2025 incident involving U.S. Ambassador to Israel Mike Huckabee, who called a settler attack on a Palestinian church in the West Bank town of Taybeh “an act of terror.” When such hits occur, these tools generally produce automatic “red flags” against people who have been previously targeted with U.S. sanctions and/or subjected to sanctions by other jurisdictions. The “red flags” then need to be escalated for review within the bank or company for a determination about whether the transaction should be processed — an answer that will differ depending on each entity’s internal policies and procedures. Negative news leading to ongoing red flags, including the precedent of the U.S. imposing sanctions, makes things more challenging for sanctioned individuals and entities because banks will often decline to process transactions on their behalf to avoid risk.
Notwithstanding the above, it is clear that the U.S. did not achieve its broader policy objective of disrupting the system that supports settler violence at a more fundamental level. Extreme settler violence is currently increasing, and Israel’s West Bank policies have not changed meaningfully as a result of the sanctions. Indeed, in video footage of a shocking recent incident, one of the previously sanctioned settlers (who remains under sanctions across all of the other jurisdictions listed above), Yinon Levi, is seen shooting and killing an unarmed Palestinian activist, Awdah Hathaleen, in broad daylight and with numerous witnesses — further evidence that the sanctions did not contribute to a broader shift in behavior.
Some critics of the sanctions have noted that the Biden administration undermined its own efforts when, in March 2024, it sent a letter to the Bank of Israel authorizing it to process certain kinds of payments on behalf of people targeted by sanctions, principally for essential purchases such as food, shelter and child care. This criticism was misplaced, given that issuing a form of “living license” is standard practice in sanctions programs.
Similarly, when Amana was targeted in November 2024, the Biden administration issued a 60-day “wind-down” license, which allowed any U.S. person or business to take actions to separate themselves from Amana. This is also standard practice, but the actual designation lasted only a few days before President Donald Trump rescinded the sanctions on his first day in office.
To some degree, the limited impact of the sanctions is to be expected. Sanctions can’t stop wars once they start; similarly, a sanctions program in place for less than a year cannot fully change the trajectory of a policy that has been in place for decades. Nor will sanctions stop individual settlers from committing specific and discrete acts of violence, as Levi did when he shot and killed Hathaleen in July 2025. Only law enforcement can do that. Sanctions can only help encourage law enforcement to do so more often.
When Trump terminated the executive order and the sanctions on specific targets, reactions were split along ideological lines. The Israeli government cheered, and the Palestinians condemned. U.S. lawmakers who support the settlements and who had criticized the Biden administration praised Trump’s move, while others who had supported the Biden-era sanctions were critical and have sought to maintain pressure on settlers and related entities through other means. For example, in June, Rep. Jerry Nadler, a Democrat from New York, introduced the West Bank Violence Prevention Act of 2025, which now has 48 co-sponsors. Meanwhile, settler violence has continued to escalate throughout 2025, resulting in repeated international condemnations.
To understand the direction the sanctions took and evaluate whether they had an impact, it is essential to understand how they function. The president cannot simply decide that sanctions should be implemented but must first declare in an executive order, which must be renewed annually, that a given situation is a national emergency, and then decide what tools and authorities to delegate to agencies within the administration to deal with the problem. In the text of his Feb. 4, 2024, executive order announcing the implementation of sanctions, President Joe Biden described the emergency as follows:
The situation in the West Bank — in particular high levels of extremist settler violence, forced displacement of people and villages, and property destruction — has reached intolerable levels and constitutes a serious threat to the peace, security, and stability of the West Bank and Gaza, Israel, and the broader Middle East region. These actions undermine the foreign policy objectives of the United States, including the viability of a two-state solution and ensuring Israelis and Palestinians can attain equal measures of security, prosperity, and freedom. They also undermine the security of Israel and have the potential to lead to broader regional destabilization across the Middle East, threatening United States personnel and interests. For these reasons, these actions constitute an unusual and extraordinary threat to the national security and foreign policy of the United States. I hereby declare a national emergency to deal with that threat.
Once the emergency is declared, the president identifies what actions should be used to deal with the situation. In this case, the primary action was a targeted asset freeze, though visa bans were also used. This means that the president sets out criteria for who can be named to the Specially Designated Nationals and Blocked Persons List (SDN List), maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). This is the overarching list that includes everyone who has been sanctioned across all sanctions programs, from those levied on Russia and Iran to the effort to counter cartels and narco-traffickers.
In the West Bank case, those criteria were broad but also quite specific. For example, anyone the U.S. determined was responsible for threatening the “peace, security, or stability of the West Bank” or planning or participating in acts of violence against people could be sanctioned. Similarly, settlers who tried to confiscate land from Palestinians, who destroyed Palestinian property or who dispossessed Palestinians could be targeted.
The government can also add to the SDN List any person who provides “material support” or “financial assistance” to the sanctioned individuals or entities. The U.S. dollar bank accounts and transactions of a person who is named on the list are blocked or frozen (not seized). With the exception of certain exempt cases, no U.S. person can engage in any business or transactions with that person. A major consideration then, in any targeting scenario, is understanding whether the individual or entity does business with the U.S. or has U.S. connections.
The U.S. government does not name everyone and anyone who could meet those criteria to the SDN List, partly because it lacks the administrative resources to do so and partly because the goal is to choose targets that will have a specific impact. This is usually to advance a policy objective and, if possible, disrupt financial flows or economic benefits that an individual targeted by sanctions derives from being involved in the problematic activity. In this case, the goal was to target the people mobilizing, directing and fundraising for settler violence.
Sanctions are analogous to a punch in the face. Sometimes, one punch is all that’s needed to get someone to change their tune and go in a different direction. But usually it takes more than that, especially when the problem is entrenched and complex. Law enforcement authorities can’t take out a gang dominating a city by punching its leader in the face just once. Often, when someone gets up from a punch in the face, they will go back to what they were doing before — perhaps with even more resolve in the short term.
In the sanctions world, that is often when “work-arounds” and evasion begin. Once those work-arounds take hold, critics of sanctions will generally say, “See, sanctions have failed because they can be evaded.” But the more nuanced and appropriate critique at that point is to say the policy and diplomacy failed because the battered target wasn’t given a new option while dazed and disrupted. The punch usually works; it’s the cleanup that needs to get better.
There are innumerable media and academic articles, panel discussions and podcasts assessing whether sanctions “worked” in any specific case, though often mistakenly taking the “behavior change” question as the basis for evaluation, rather than the more limited and appropriate “behavior disruption” approach. Few of these observers understand that a specific sanctions action may not be designed to achieve the entirety of the policy’s objective.
In general, when the objective is more focused and limited, sanctions tend to be more effective because there can be a clearer line between the tool and the objective. As noted above, it is unlikely that sanctions can, for example, stop a war or end long-standing, entrenched situations like Israel’s occupation of the West Bank. The hope, however, is that by disrupting one component of a broader problem, leverage can be developed.
There are numerous examples of when this has happened. In Congo, a series of escalating sanctions was imposed between 2016 and 2018 in an effort to convince then-President Joseph Kabila not to change the constitution and run for a third term. Diplomacy was led at high levels by then-U.S. Ambassador to the U.N. Nikki Haley, and the goal was achieved. Again, there were many tools and factors involved, but sanctions were clearly among them. And the goal of these designations was not to achieve a comprehensive end to the country’s complex and ongoing challenges.
Between 2021 and 2023, in response to the coup and ongoing atrocities committed by the junta in Myanmar, sanctions contributed to a meaningful degradation of the country’s military capabilities. In particular, policy was focused on shrinking the junta’s access to U.S. dollars by sanctioning major state-owned enterprises and key banks, while engaging diplomatically with regional trading and financial centers such as Singapore and Thailand so that they respected and enforced these actions. The result was a surprising series of battlefield defeats starting in October 2023. The Biden administration then moved away from using sanctions in 2024, an approach the Trump administration has maintained. The junta now appears to be rebounding from the toll those earlier punches took.
Perhaps most notably, and regardless of one’s view of the ultimate policy objective, the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA) negotiated between 2013 and 2015 was undoubtedly achieved as a result of sustained and escalating sanctions pressure. Here, too, the focus was on one aspect of Iran-related policy. The narrower concentration on the nuclear issue, to the exclusion of others, was ultimately what led to the policy’s undoing, but it was the key factor in ensuring the sanctions were effective.
Economic sanctions programs tend to last for many years, often decades. Rarely is a sanctions program terminated in less than one year, as it was in the case of Israel, especially before the underlying problem is “solved.” For example, in the case of Zimbabwe in 2024, the Biden administration terminated a 22-year-old sanctions program because, even though U.S. policy toward the government of Zimbabwe had not changed, the tool of sanctions had ceased to have the desired impact. The punches had worn off, and a new approach was needed.
In the West Bank case, the punches had not worn off and were having an impact on the targets, but then the policy changed. That is the nature of a policy tool; it is dependent on the policymaker.
Most sanctions programs succeed in some ways and fail in others. As the Trump administration considers rolling back some aspects of the sanctions on Russia, many postmortems will be written on how they worked, and just as many on how they failed. Some elements of all those forthcoming analyses will be correct, depending on how they assess the policy objective and the tools deployed.
Just make sure you see how they judge a punch.
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