The GHOST Act of 2025 aims to enhance enforcement of sanctions against Russia and strengthen export control measures through financial resources and interagency coordination.
Joni Ernst
Senator
IA
The GHOST Act of 2025 aims to enhance the enforcement of sanctions against Russia by establishing a fund within the Treasury to cover expenses related to seizing assets from sanction violations and covered merchant ships. It also establishes an Export Enforcement Coordination Center within Homeland Security Investigations to serve as the primary point of contact for federal export enforcement efforts, fostering collaboration among various agencies to prevent export control violations. The fund will be used for investigative costs, property maintenance, compensation for informers, and other related expenses, while the center will facilitate information sharing, coordinate public outreach, and improve investigations into export control violations. The Act authorizes appropriations for the fund and outlines reporting requirements to Congress, ensuring transparency and accountability in its operations.
New GHOST Act Targets Russian Sanction Evaders with $150M Seizure Fund, Centralizes Export Enforcement
The GHOST Act of 2025 aims to put more muscle behind enforcing sanctions against Russia and tighten the net on illegal U.S. exports. It tackles this on two fronts: first, by creating a dedicated "Russia Sanctions Enforcement Fund" starting with a $150 million appropriation for fiscal year 2026 (Section 2). This money is earmarked for the costs associated with investigating and seizing property tied to Russian sanctions violations, with a specific focus on grabbing oil, petroleum products, or other commodities used in smuggling schemes. Second, the act formally establishes and beefs up the Export Enforcement Coordination Center (E2C2) within Homeland Security Investigations (Section 3), acting as a central hub to get various government agencies working together more effectively on stopping illegal exports.
Hitting Where It Hurts: The Sanctions Seizure Fund
Think of this new fund as the operational budget for chasing down assets linked to dodging Russian sanctions. Section 2 outlines how the Department of Homeland Security (DHS) and the Department of Justice (DOJ) can tap into this money for everything from investigation costs and managing seized property (like impounded ships or frozen bank accounts) to paying informants for crucial tips and even buying specialized equipment for law enforcement partners. The fund has an initial $150 million injection, authorized for Fiscal Year 2026, which needs to be repaid to the Treasury by late 2036. It’s capped at a $500 million balance annually (adjusted for inflation), with any extra cash going back to the general Treasury fund. To keep things transparent, the DHS Secretary has to submit annual reports detailing how the money was spent, what was seized, and even explaining any policy decisions not to pursue a seizure. Failure to report on time triggers financial penalties, transferring portions of the fund back to the Treasury.
Untangling the Web: The Export Enforcement Hub
On the export control side, Section 3 doesn't necessarily create brand new powers but aims to make existing enforcement smarter and more coordinated. It solidifies the Export Enforcement Coordination Center (E2C2), previously established by Executive Order, placing it firmly within Homeland Security Investigations (HSI). The goal is to make E2C2 the primary point of contact for federal efforts policing what goods and technologies leave the U.S. This means getting agencies like Commerce (which handles export licenses), Justice (which prosecutes violations), State, Defense, Treasury, Energy, and the Intelligence Community talking and sharing information more effectively. The Center will coordinate investigations, track enforcement stats government-wide, and manage public outreach. It brings together liaisons – agents, analysts, officers – from a wide array of agencies, from the FBI and ATF to military investigative services and intelligence bodies, all under HSI leadership with deputies from Commerce and Justice. The idea is to prevent different agencies from working in silos or duplicating efforts when trying to stop sensitive technology or weapons from falling into the wrong hands.