GHOST Act Creates $150 Million Fund to Seize Russian Assets, Giving DHS Broad Spending Power

The Global Hunt for Offshore Smuggling and Trafficking Act of 2025, or the GHOST Act, is essentially a turbocharger for U.S. sanctions enforcement against Russia. This bill doesn’t create new sanctions; it creates a dedicated, self-sustaining financial mechanism and a new coordination hub designed to make sure the existing sanctions actually stick.

The Russia Sanctions Enforcement Fund: A Dedicated War Chest

The centerpiece of the GHOST Act is the creation of the Russia Sanctions Enforcement Fund, a new pot of money inside the Treasury dedicated solely to paying for the seizure and forfeiture of assets tied to Russian sanctions violations (SEC. 2). Think of it like an expense account for law enforcement, but one that gets refilled by the assets it seizes. Congress is authorized to kick things off with $150 million for fiscal year 2026, which can be spent until it runs out, and the fund must eventually pay that initial investment back to the Treasury by September 30, 2036.

This Fund gives the Administrator, appointed by the Secretaries of Homeland Security and the Treasury, broad authority to spend money without needing extra approval each time, as long as it relates to a seizure. This covers everything from paying for investigative work and securing seized property (like superyachts or frozen bank accounts) to hiring specialized contractors to manage and sell off those assets for the best return. Crucially, the Fund is authorized to pay rewards to people who provide tips that lead to a successful seizure, which is a major incentive for whistleblowers.

The Fine Print on Spending and Oversight

While the goal is solid—stiffening enforcement—the mechanism comes with some notable wrinkles. The Secretary of Homeland Security can direct the Fund to pay for equipment, such as specialized gear for vessels or aircraft, for federal, state, and local agencies working on these seizures. This means the Fund could potentially become a major source of equipment procurement for law enforcement, provided it’s tied to sanctions enforcement activities. Furthermore, the Administrator is specifically instructed to prioritize activities that lead to seizing oil, petroleum products, or other commodities that are funding Russia’s evasive actions, meaning the focus is squarely on cutting off revenue streams.

There are also strict financial guardrails: the Fund has a maximum balance limit of $500 million (adjusted for inflation) each year, and any excess cash must be sent to the Treasury to reduce the public debt. However, a significant oversight concern is the penalty for non-compliance with reporting rules. If the required detailed annual report is 180 days late, 5% of the Fund’s balance is automatically transferred to the Treasury. Even more striking, the President can use a national security waiver to keep the Fund operating, even if mandatory termination conditions are met, effectively bypassing this reporting accountability if the Administration deems it necessary for national security.

The Export Enforcement Coordination Center: Getting Everyone on the Same Page

In addition to the money, the GHOST Act establishes the Export Enforcement Coordination Center (EECC) within Homeland Security Investigations (HSI) (SEC. 3). If the Fund is the wallet, the EECC is the central nervous system. This Center is designed to be the single point of contact where nearly every federal agency involved in export controls—from State and Commerce to Treasury, Justice, and the entire Intelligence Community—can coordinate their efforts.

For businesses and manufacturers, especially those dealing with dual-use technologies (items that have both commercial and military applications), this is a big deal. The EECC will streamline how law enforcement and intelligence agencies share information about potential violations of export rules, making enforcement efforts much more targeted and efficient. This means that if you’re a company exporting goods, the federal government’s enforcement efforts will be highly coordinated, reducing the chance that illegal shipments slip through the cracks due to poor interagency communication.