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10/20/2021

Testimony of Deputy Secretary of the Treasury Wally Adeyemo before the Committee on Banking, Housing, and Urb…

Testimony of Deputy Secretary of the Treasury Wally Adeyemo
before the Committee on Banking, Housing, and Urban Affairs,
U.S. Senate
October 19, 2021

As delivered:
Chairman Brown, Ranking Member Toomey, and Members of the Committee, thank you for
giving me the opportunity to speak to you today about the National Advisory Council on
International Monetary and Financial Policies (NAC) report to Congress, the Treasury
Department’s priorities, and our outlook for the global financial system.
As you know, the International Financial Institutions form the core of an international
financial architecture that is consistent with our economic interest. It is no accident that the
U.S. economy is the largest in the world, that our financial markets are the deepest and the
most liquid, and that the dollar is the world’s reserve currency. Our economic success is the
result of the policy choices we made coming out of World War II, alongside the hard work
and determination of the American people.
America’s interest in a strong, stable, and rules-based economic order is also deeply
entwined with our foreign policy and national security interests. Our economic objectives
cannot succeed if the international financial system facilitates the illicit flow of funds to
oppressive regimes, terrorist groups, cyber criminals, and other malign actors. Bearing this in
mind, Secretary Yellen requested a review of Treasury's use of financial and economic
sanctions since the terrorist attacks of September 11, 2001.
The review identified four primary challenges to the continued e ectiveness of our sanctions
regimes: (1) our adversaries’ attempt to build payment systems that allow them to avoid the
dollar based financial system; (2) technological changes like the growth of digital currencies;
(3) the need to permit the flow of legitimate humanitarian assistance and avoid collateral
impact on non-target populations; and finally, (4) ensuring that sanctions are always
deployed alongside other measures as part of an overarching national security strategy.

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10/20/2021

Testimony of Deputy Secretary of the Treasury Wally Adeyemo before the Committee on Banking, Housing, and Urb…

I want to briefly describe to the Committee the five initiatives Treasury is advancing to
respond to these challenges and modernize the use of sanctions:
1. Adopting a Policy Framework – Treasury will adopt the use of a structured policy
framework in order to inform its recommendations on the use of sanctions. This
framework will seek to ensure that sanctions support clear policy objectives within a
broader strategy; reflect input from technical experts and other critical sources of
information including the intelligence community; incorporate multilateral cooperation;
and are easily understood, enforceable, and reversible. The framework will be a tool to
improve the use of sanctions, not a means to prevent it.
2. Improving Access to Humanitarian Assistance – Treasury will work to expand sanctions
exceptions, where appropriate, to support the flow of legitimate humanitarian
assistance, incorporating lessons learned from the last 20 years. The Department is
committed to consistently providing clear guidance in the context of all applicable
sanctions regimes, including the continued flow of legitimate humanitarian aid to heavily
sanctioned jurisdictions.
3. The Regular Assessment of Sanction Programs – Treasury plans to use the sanctions
policy framework on a regular basis to review sanctions programs and authorities and
make recommendations to augment, adapt, or wind down individual authorities or to list
or delist particular entities.
4. Improve Sanctions Coordination and Communications – The threat of sanctions alone
—not even the imposition—remains a powerful tool of economic statecra . In order to
calibrate the use of this tool, Treasury needs to communicate and coordinate more
e ectively with stakeholders a ected by the use of financial sanctions. This includes U.S.
allies and partners, financial institutions and other actors within the financial system,
nonprofit organizations, and the media. We will do this by using existing forums where
we meet with our allies and partners to coordinate and collaborate on sanctions, as well
as building a more formal mechanism for receiving feedback and advice and providing
information to stakeholders.
5. Modernize our Operational Capabilities – As the threats to our nation change, sanctions
must also adapt. Treasury must invest in changes to its workforce and technical
capabilities to meet these evolving threats. This will involve streamlining current
functions, as well as making workforce and infrastructure investments to take on
growing threats like ransomware and other cybercrime.
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10/20/2021

Testimony of Deputy Secretary of the Treasury Wally Adeyemo before the Committee on Banking, Housing, and Urb…

This e ort will require building on current processes in some areas and changes in others.
Some changes may be implemented in the near-term, while others will require further
deliberation and analysis to determine the best path forward in collaboration with the State
Department and other executive branch partners. In many cases, support and advice from
key partners, like Congress, will be critical.
Members, sanctions are not only an important tool for the United States ; they play an
important role in maintaining the rules-based global economy, which has benefited the
world for generations. I look forward to working with members of this committee to
continue advancing U.S. international economic leadership abroad and creating
opportunities for Americans at home.
I’m happy to take your questions.
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