PolicyBrief
H.R. 4291
119th CongressJul 2nd 2025
Sanctions Lists Harmonization Act
IN COMMITTEE

This bill mandates that federal agencies quickly share information about newly sanctioned individuals and entities across designated sanctions lists to ensure consistent and timely enforcement.

Randall "Randy" Fine
R

Randall "Randy" Fine

Representative

FL-6

LEGISLATION

Interagency Sanctions Bill Mandates 90-Day Review for Blacklisted Companies and Individuals

The newly introduced Sanctions Lists Harmonization Act is an administrative bill focused on tightening up how the U.S. government applies existing sanctions. Essentially, it mandates that if one federal agency—like the Treasury Department—puts an individual or company on a sanctions list, they must notify the other relevant agencies within 30 days. The receiving agencies then have a strict timeline: 30 days to start a review and 90 days to decide whether to add that same individual or entity to their own corresponding sanctions lists, ensuring a unified front across government blacklists.

Why the Government Needs to Get Its Lists Together

Think of this bill as a mandatory upgrade to the government’s internal communication system for bad actors. Currently, if the Treasury Department adds a company to its Specially Designated Nationals (SDN) List for funding terrorism, the Commerce Department might not immediately know to add that same company to its Military End User List to block exports. This bill closes that gap. It covers six specific lists, including those maintained by the Treasury, Commerce, and Defense Departments, which target everything from foreign adversaries to entities involved in military-industrial complexes.

The Real-World Speed Bump

For the average person, this bill doesn’t change much about daily life, but it has a huge impact on anyone who interacts with the global financial system or deals in international trade. If you’re running a small manufacturing business that relies on exporting components, the speed and breadth of sanctions matter. Previously, a sanctioned entity might have had a window of opportunity to shift assets or complete a transaction before all agencies caught up. This bill drastically shrinks that window. By forcing a 90-day maximum turnaround for cross-listing, the government ensures that when sanctions hit, they hit fast and across the board. The goal here is efficiency and consistency, making it much harder for sanctioned parties to operate anywhere in the U.S. financial or trade system.

Congressional Oversight and the Paper Trail

This act also includes a significant reporting requirement aimed at accountability. About one year after the law takes effect, every agency maintaining one of the covered lists must report back to specific Congressional committees (like Foreign Affairs and Financial Services). This report must confirm they followed the new notification and review rules and explain why they decided to add—or not add—names to their lists. This means Congress gets a clear look at the agencies’ decision-making process, which adds a welcome layer of transparency to the usually opaque world of sanctions enforcement. While the report must generally be public, the bill notes that classified sections can be included, which is standard practice when dealing with national security information.