The Sanctions Switch: Zimbabwe as a Model for a New Approach

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Report by Judd Devermont and Brad Brooks-Rubin

Published April 28, 2026

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Two years ago, the U.S. government took an action it almost never takes: It sunset an economic sanctions program that was past its prime. It was a remarkable step because it was not preceded by a regime change or an end to a bloody civil conflict—just a recognition that the program had become unmoored from any clear strategic purpose. It had become a burden, not a benefit, to U.S. policy goals. Rather than stick with the status quo, the U.S. government resolved to undertake a radical makeover. It was an unprecedented action, and yet, it is still largely unknown outside a small policy community.

That sanctions program focused on Zimbabwe. It was originally imposed in 2003, and it quickly ballooned to include some 200 senior government officials and ruling party leaders for the Zimbabwe African National Union-Patriotic Front (ZANU-PF), as well as their family members, state-owned entities, and private companies. It was, by far, the largest sanctions program targeting any African country. Paired with the Zimbabwe Democracy and Economic Recovery Act (ZDERA), signed into law in 2001, these sanctions effectively isolated the Zimbabwean government for its human rights abuses, election manipulation, and endemic corruption. The program, however, soon became unfocused and unhelpful—a policy albatross that attracted continent-wide criticism while failing to induce constructive change. It had to be reformed.

Removing a sanctions program when a policy goal has been unmet is a challenging endeavor. Too often, stakeholders mistake sanctions for policy, or worse, for strategy, and become wedded to the status quo.

Removing a sanctions program when a policy goal has been unmet is a challenging endeavor. Too often, stakeholders mistake sanctions for policy, or worse, for strategy, and become wedded to the status quo.

Removing a sanctions program when a policy goal has been unmet is a challenging endeavor. Too often, stakeholders mistake sanctions for policy, or worse, for strategy, and become wedded to the status quo. As the senior director for African affairs at the National Security Council and senior advisor to the sanctions coordinator at the State Department during the Biden administration, the authors worked closely with key colleagues at the Treasury Department and across the interagency to carefully choreograph this move—without inciting domestic and foreign blowback. To be sure, the success of this approach is still being debated, and it likely will continue to be under scrutiny for several years, especially so long as the Zimbabwean government continues to perpetuate human rights abuses and indulges in widespread corruption. Nonetheless, it is an important case study for a clear-eyed assessment of the utility of specific sanctions programs and what one can do to reimagine dated programs to ensure they stay relevant to current policy goals and strategic objectives.
 

The Road to Sanctions

When Zimbabwe finally gained independence in April 1980, the United States rushed to embrace the new nation. President Jimmy Carter welcomed Prime Minister Robert Mugabe to the White House in August of the same year, stating that “on all too rare occasions, there is achieved a result which thrills the entire world, based on decency, based on freedom, based on independence, based on equality, and based on human courage.” U.S. ties with Zimbabwe, however, started to buckle in response to the government’s crackdown on the opposition, resulting in the massacre of about 20,000 people from 1983 to 1987. These bilateral tensions were not enough to cause the relationship to break; indeed, U.S. ambassadors in the 1990s professed to have had positive engagements with Mugabe, recalling that “he was behaving internationally and regionally much more responsibly.”

The turn to a more adversarial relationship stemmed partly from the Zimbabwean government’s abysmal economic stewardship. Mugabe needed a scapegoat for the country’s woes, so he blamed white farmers and backed land seizures by ruling party thugs and “war veterans” as part of a new land reform program. At the same time, Mugabe rammed through a series of constitutional amendments designed to entrench his power. The U.S. Congress, accordingly, passed ZDERA in 2001, which prohibited U.S. support for multilateral debt relief and credit for Zimbabwe’s government pending free and fair elections, credible land reform, security force subordination to civilian leadership, and adherence to the rule of law. This set the stage for the executive branch to take further action, using the relatively new approach of individual and entity sanctions targeting rather than the older sanctions model, which had tended to rely on country-level embargoes.

A Short Detour: Sanctions Primer

Although the subject of how sanctions are imposed, what they do, and how they are governed can be a long and complicated one, there are a few salient points to understand what happened in Zimbabwe’s case.

Sanctions in the United States, by and large, are imposed by presidents through the issuance of an executive order (EO) authorized by the International Emergency Economic Powers Act (IEEPA), a somewhat obscure law passed during the Carter administration that has only recently become part of our political vernacular due to President Trump’s tariffs and the Supreme Court decision upending them. IEEPA-based sanctions, like those related to Zimbabwe, require the declaration of a “national emergency” to deal with an “unusual and extraordinary” threat to the national security, foreign policy, or economy of the United States.

The president then identifies what steps will be taken to deal with that emergency. Sanctions are intended to be tools of foreign policy, designed to help gain leverage to advance specific U.S. policy objectives. Until the mid-1990s, those steps tended to be country-level embargoes, which included Rhodesia between 1966 and 1979 and, more famously, Cuba since its 1959 revolution. But following the criticism of the sanctions imposed on Iraq in the early 1990s, President Bill Clinton shifted to more targeted sanctions, in which the focus was asset blocking, or freezing, of individuals and entities determined to meet certain criteria. The criteria that can result in a person being sanctioned range from “conduct-based” (e.g., committing human rights violations, engaging in corruption, or undermining U.S. policy through certain acts or omissions) to more status-based (e.g., being a member of a government, operating in a specific sector of a country’s economy, or being the family member of a sanctioned person). The latter can apply not only to individuals but also to specific assets—such as vessels or aircraft—that are owned or controlled by a sanctioned entity. The theory, of course, was that by shifting the focus to certain people and entities, broad impact on the population could be avoided, while those responsible for problematic behavior could be disrupted and, in theory, compelled to change that behavior.

Once an EO is issued, agencies, principally the Treasury Department’s Office of Foreign Assets Control (OFAC) and the State Department, then set about identifying, researching, and eventually announcing sanctions targets after thorough interagency review. After a target is designated, no U.S. person can deal with them, and all U.S. assets held by the target are blocked. Importantly, this also extends, in practice, to any transactions in U.S dollars. In some cases, the United States will also seek to have similar action taken by allies or even the UN Security Council to broaden and deepen the impact.

For many reasons, sanctions are hard to remove other than in cases where a remarkable change has occurred; even when a change has happened, sanctions can linger. The fact that Nelson Mandela was stuck on a terror list until 2008 is telling. Few policymakers want to end something as serious as a declared national emergency absent a compelling reason to do so. In cases where little has changed following the imposition of sanctions, even fewer policymakers are willing to admit that a policy failed to achieve its ends, especially given the likely propaganda win it offers to the former sanctioned individual or entity. The problem is that there is rarely a clear sense at the time of imposition of what precise behavior change should look like or whether there is a willingness to ease sanctions absent a major public shift by the target; in some cases, not even a target’s death may be sufficient, for fear of misuse of blocked assets by survivors.  

Greenlighting Zimbabwe Sanctions

In the case of Zimbabwe, three EOs were issued by President Bush between 2003 and 2008, generally in line with similar actions taken by the United Kingdom. The first EO (EO 13288) declared the national emergency to be based on “the actions and policies of certain members of the Government of Zimbabwe and other persons to undermine Zimbabwe’s democratic processes or institutions, contributing to the deliberate breakdown in the rule of law in Zimbabwe, to politically motivated violence and intimidation in that country, and to political and economic instability in the southern African region.”

Unlike current best practices, where targeting is undertaken through the issuance of steady and slowly escalating tranches of sanctions that can be carefully messaged to the targets (and those not yet targeted), EO 13288 targeted 77 high-level individuals, companies, and properties at once, up to and including President Mugabe and senior officials of ZANU-PF, their family members, and most key entities and companies in the Zimbabwean economy. Similarly, there were no substantive criteria in the EO; the names were simply listed in an annex without explanation as to what they were alleged to have done or, importantly, what they may be able to do to be removed from the list. (Note: This was not sloppy or incomplete work, but rather it reflects how presidential annexes and Treasury sanctions packages were constructed and issued in the early, post-9/11 period, when the use of sanctions began to truly transform. By the late 2000s, those practices had evolved further into the practices generally seen today.)

The subsequent EO in 2005 (EO 13391) expanded the sanctions target list to a total of 128 individuals and 33 entities, principally the farms from which white farmers had been evicted. EO 13391 also added one substantive sanctions criterion—“to have engaged in actions or policies to undermine Zimbabwe’s democratic processes or institutions”—as well as derivative criteria related to those targets (i.e., their family members, those providing assistance to them, and any property they owned). This allowed for more designations in the subsequent years. By 2008, when the final EO (EO 13469) was issued, there was more focus and transparency—in line with current practices. This EO expanded the criteria to include anyone who was a “senior official of the Government of Zimbabwe” or involved in human rights abuses, political repression, or public corruption.

The response from Zimbabwe was strong and immediate, and it remained consistent during the two-plus decades the sanctions were in place. President Mugabe and ZANU-PF denounced the sanctions in the strongest terms—for example, “racist, “neo-colonialist” and “illegal.” ZANU-PF quickly turned them into a propaganda tool, blaming sanctions for the economic ills of the country, alleging losses in the hundreds of billions.  

Searching for an Off-Ramp

By the time President Joe Biden entered the White House in 2021, the Zimbabwe sanctions had become a procedural irritant at best and a policy obstacle at worst. To be clear, the Zimbabwean government remained unrepentant, despite a government of national unity with the opposition between 2009 and 2013 and Mugabe’s dramatic ouster from power in 2017 by his longtime comrade-in-arms Emmerson Mnangagwa.

The challenge, unfortunately, was that the sanctions program had become a distraction and increasingly indefensible. For a variety of reasons, the sanctions became more or less the only policy topic or debate in the bilateral relationship with Zimbabwe, overshadowing hundreds of millions of dollars of assistance provided by the U.S. government and other avenues of engagement. For ZANU-PF, fighting the sanctions became something of a raison d’être, and the United States too often could not point to the larger policy or strategy the sanctions were supposedly advancing. Many inside the U.S. government, as well as the Zimbabwean government and other stakeholders, increasingly felt that the sanctions themselves had become the policy, rather than a tool to advance policy.

In the intervening years, to try to ease these pressures, efforts had been made to cull the sanctions list to remove individuals who had died, were no longer active in politics, or had made clear breaks from ZANU-PF. Importantly, additions were also made, principally targeting so-called foreign enablers, such as Chinese investor and arms dealer Sam Pa and Kudakwashe Tagwirei, one of the key business partners of President Mnangagwa.

As discussions began at the State Department in the fall of 2022 to consider ending or transitioning the sanctions program, there were close to 100 individuals and entities remaining on the sanctions list connected to Zimbabwe. Despite regular efforts to update the list, there were designated individuals who had passed away (Mugabe, most notably). It was hard to even verify who or what some of the named individuals or farms were and why they were on the list in the first place, since the original listings did not come with a press release or a designation criterion. Moreover, the U.S. government was facing legal challenges from some former regime officials to get off the list. In other words, there was a clear need for some policy hygiene and a thorough scrub of the program.

Prioritizing Teamwork

The deeper issue affecting U.S. policy objectives, however, was that Zimbabwe sanctions had become a factor in U.S. relations with the rest of southern Africa. In 2019, the Southern African Development Community (SADC) designated October 25 as “a day for solidarity against sanctions imposed on Zimbabwe by the European Union, United States, and United Kingdom.” The Zimbabwean government had managed to reframe for its population and the broader region that it was the sanctions that were responsible for the country’s economic woes, which resulted in a flood of migrants into neighboring countries. It had become a cause célèbre, with an annual SADC celebration every year. In fact, African leaders started to raise the issue with Biden, including South African President Cyril Ramaphosa in the Oval Office in September 2022. U.S. policy goals in the region were at risk of being derailed by the sanctions debate. The Biden administration decided it needed to reevaluate the program, revamping it to better align with current policy objectives.

This became a guiding principle for the sanctions rethink. It was imperative to work with regional partners in any shift in U.S. approach toward Zimbabwe. This collaboration was integral to success. If a new approach generated further criticism from southern African governments, it was all for naught. And, conversely, if there was public support, or even a muted response, it would validate the entire exercise. Thus, U.S. officials initiated a dialogue with counterparts in the region about revising sanctions. It happened in Washington, D.C., coffee houses and in African capitals, even on the margins of the U.S.-Africa Business Summit. To be clear, the United States was not jointly plotting every step with its regional counterparts (or even agreeing on the final outcome), but there were important temperature-takings and quiet discussions about what progress might look like. This was invaluable to developing an approach that could adjust the way the United States used the sanctions tool while remaining focused on a strong policy overall on Zimbabwe. 

Moving in a New Direction

The task the U.S. government set out for itself was significant: How does one retire an increasingly problematic sanctions programs without giving a free pass to a regime that continued to commit gross abuses of political, economic, and human rights? Fortunately, there was a new tool the U.S. government could turn to. The Global Magnitsky program (GloMag) was passed as a law by Congress at the end of the Obama administration and implemented by the first Trump administration in late 2017 through EO 13818. GloMag targets those responsible for serious human rights abuse or corruption anywhere in the world. Thus, there previously would have been essentially a binary choice: either removing the sanctions entirely and then dealing with the potential fallout or maintaining the program and continuing the messaging that was no longer landing with the intended audiences. GloMag presented a third way, which offered several advantages, including the following:

As noted above, the Zimbabwe program already included human rights abuse and corruption as key criteria, such that the evidence and messaging would easily align.

GloMag is a global program, allowing the administration to reference Zimbabwe’s targets alongside those from around the world and enabling a move away from singling out Zimbabwe as a national emergency over many other countries facing serious human rights and corruption issues that were not subject to the same treatment.

GloMag had been positively received as a sanctions tool by SADC members (at least privately), particularly South Africa in the context of the designation of the Gupta network and Angola in the case of a network that had embezzled billions.

It enabled the United States to update its approach, refocusing on new instances of corruption, such as Zimbabwe’s role in a massive, sophisticated network of gold smuggling and money laundering. It recentered U.S. sanctions on current violations, not actions perpetrated decades ago.
 

The decision to switch sanctions programs was not made overnight. U.S. officials spent close to two years, starting in the fall of 2022, to develop a plan of action and consult widely about the best way forward. In contrast to some policy actions, it was a truly deliberative process, which included direct and indirect conversations with congressional staffers, U.S.-based activists focused on Zimbabwe, and a handful of African officials. It also benefited from having a champion in the White House, providing focus and top cover for a major change in approach to achieve U.S. policy goals. This allowed U.S. officials to stress-test the idea, incorporating constructive feedback and securing buy-in from key stakeholders. While some interagency colleagues wanted to immediately dismantle the program, the consensus decision was to proceed slowly to keep different constituencies on board. In December 2022, the United States designated four Zimbabwean individuals (including President Mnangagwa’s son) and two Zimbabwean entities under various criteria pursuant to EOs 13391 and 13469, while removing seventeen Zimbabweans at the same time.

The task the U.S. government set out for itself was significant: How does one retire an increasingly problematic sanctions programs without giving a free pass to a regime that continued to commit gross abuses of political, economic, and human rights?

The task the U.S. government set out for itself was significant: How does one retire an increasingly problematic sanctions programs without giving a free pass to a regime that continued to commit gross abuses of political, economic, and human rights?

By the late summer of 2023, the U.S. government initiated the painstaking process of prioritizing and reviewing information on the list of those sanctioned to see who would merit continued targeting (and about whom appropriate evidence could be identified) and who would be removed. The United States reacted to unfolding events, including another flawed election, which the U.S. embassy opined “did not meet many regional and international standards.” Further, in early 2024 the United States paused participation in the Zimbabwe Structured Dialogue Platform on Debt Clearance with creditors and development partners. It was a strategic decision—a prelude to the sanctions action—meant to underscore that the United States would remain attentive to abuses, including the brutalization of the opposition following the election. Finally, in March 2024, it was time to move.
 

Crossing the Finish Line

When President Biden terminated the old executive orders and OFAC concurrently designated President Emmerson Mnangagwa and 10 others, along with three entities, for serious corruption and human rights abuses, this action almost immediately achieved its near-term objective. The United States had refocused its sanctions program and targeted those most responsible for gross abuses of political, economic, and human rights, while depriving the Zimbabwean government of its favorite scapegoat. Indeed, Harare struggled to deliver a coherent response, both claiming a diplomatic victory and denouncing the decision as unjust. Zimbabwean society, as expected, was divided, with some individuals arguing that “the real sanctions are gone now, so no more excuses” while others dismissed it as neoimperialism, an “illogical and unjust manner in which the US is – still – attempting to police the globe.”

Perhaps more importantly, SADC leaders welcomed the decision. Mokgweetsi Masisi, Botswana’s president at the time, applauded the move, saying it was “very, very encouraging that finally some of our calls have been responded to in ways that will help Botswana . . . to promote dialogue on aspects the Americans deem offensive with Zimbabwe.” Zambian President Hakainde Hichilema also hailed the decision as “further evidence that Pres. Biden listens to his African partners. We hope this is an opportunity for a new direction for Zimbabwe and regional engagement.” The U.S. Congress expressed general approval too; U.S. Senator Jim Risch issued a statement, noting that “sunsetting the previous Zimbabwe sanctions program and replacing it with GloMag robs the regime of excuses for its failed economy while ensuring Zimbabwe’s worst offenders remain held accountable.”

Of course, the sanctions switch did not end Zimbabwe’s annual anti-sanctions rallies or curb the government’s misdeeds, nor did it mean that Western companies could begin re-engaging in Zimbabwe without still conducting strong due diligence related to human rights, corruption, money laundering, environmental, and other issues, especially when related to gold, critical minerals, or other high-risk sectors. When any sanctions program is eased, whether in future cases like Zimbabwe’s or in more traditional scenarios such as Venezuela or Iran circa 2015, the private sector must continue to account for a broader set of issues than just sanctions compliance. Similarly, the U.S. government must then identify policy tools beyond sanctions to advance its strategy.

The sanctions shift was a success precisely because it did what was intended: change the way the United States used the tools without fundamentally disrupting its overarching policy.

The sanctions shift was a success precisely because it did what was intended: change the way the United States used the tools without fundamentally disrupting its overarching policy.

And indeed, Zimbabwe’s government has continued its crackdown on dissent—intimidating, harassing, threatening, and arbitrarily arresting journalists, political opposition members, and civil society activists, according to Human Rights Watch. It is important to remember that no one expected the change in sanctions approach to end these abuses. The policy remained focused on condemning these actions, seeking to engage the government of Zimbabwe, and working with partners and allies, including in the region, to bring these abuses to an end.  

The sanctions shift was a success precisely because it did what was intended: change the way the United States used the tools without fundamentally disrupting its overarching policy. This approach cleaned up a problematic sanctions program, allowed the United States to respond to concerns voiced by southern African partners, and updated U.S. policy to address Zimbabwe’s current corruption and abuses. Those abuses were directly targeted in December 2024, when OFAC issued a large sanctions package directed toward the “Gold Mafia” network, including both Zimbabwean actors and those in Kenya, the United Arab Emirates, the British Virgin Islands, and beyond (an action that the United Kingdom has followed). This kind of focus on a multinational network of illicit actors using corrupt means to steal the country’s resources proved the merit of shifting to GloMag and orienting the focus of sanctions on activity that would be of concern to everyone, including the Zimbabwean people.
 

Conclusion

In Zimbabwe, the U.S. government pulled off something rarely seen or heard of in the context of U.S. sanctions policy. It did not just remove a program that had not worked: The United States recalibrated its approach to counter unintended and increasingly unwanted consequences. Through careful consultations, smart sequencing, and message discipline, an important, if often unheralded, sanctions policy refresh was realized. It is a process that can and should be replicated, but certainly not recklessly. For example, there was an effort to lift ZDERA in the House of Representatives that was defeated in the Senate in December 2024. That is a different case entirely, borne out of frustration by some that ZDERA has not met its objectives. But its termination does not solve anything: It does not make it easier to invest in Zimbabwe, for instance, since ZDERA (or most of the Zimbabwean sanctions, for that matter) do not prohibit U.S. investments. ZDERA’s only punitive measure is a restriction on U.S. votes at international financial institutions.

In contrast, when the U.S. government decided to shift the Zimbabwe sanctions program in March 2024, the goals were clear and achievable. There was a thorough cost-benefit analysis, and a sensitivity to the concerns of a diverse set of U.S. and African stakeholders. It also had buy-in at the highest level with the National Security Council and officials at other departments and agencies quarterbacking the entire process. In the current administration, it is more likely that the State Department would drive the policy process due to the National Security Council’s reduced role, but the Treasury Department’s role as the lead implementer and its technical experts could also make it better suited to lead these efforts in some cases, especially where the details of the sanctions program are complicated enough that taking them down needs careful calibration.

In the final analysis, an approach that applies sanctions with an eye toward impact and bias for reform when they have run their course should be the gold standard of sanctions programs in Africa or in other regions. If sanctions are here to stay as a policy tool, then the U.S. government must be able to demonstrate that they are not simply prosecutions by administrative means that can never, or very rarely, be removed. The United States should impose sanctions only as long as they are useful.

Judd Devermont is a senior adviser (non-resident) with the Africa Program at the Center for Strategic and International Studies (CSIS). Brad Brooks-Rubin is a senior associate (non-resident) with the Human Rights Initiative and Economics Program and Scholl Chair in International Business at CSIS. 

This report is made possible by general support to CSIS. No direct sponsorship contributed to this report.

This report is produced by the Center for Strategic and International Studies (CSIS), a private, tax-exempt institution focusing on international public policy issues. Its research is nonpartisan and nonproprietary. CSIS does not take specific policy positions. Accordingly, all views, positions, and conclusions expressed in this publication should be understood to be solely those of the author(s).

© 2026 by the Center for Strategic and International Studies. All rights reserved.

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