OFAC’s Banality of Evil: Tiny US Agency Victimizing Millions of Innocent Foreigners

As tourists complete their walk to the White House from the east side along Pennsylvania Avenue, they pass a relatively nondescript columned office building overlooking Lafayette Square. They are unaware that behind the building’s walls, bureaucrats are silently sowing poverty, disease and death among countless innocent people around the world.

The Freedman’s Bank Building houses not CIA or Department of Defense officials, but the U.S. Treasury Department’s little-known Office of Foreign Assets Control (OFAC). Rather than orchestrating airstrikes or uprisings, these bureaucrats inflict mass suffering through economic warfare, collectively serving as the spearhead of America’s ever-expanding economic sanctions regime.

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The term “banality of evil” was coined by intellectual Hannah Arendt after she witnessed the 1961 trial of Adolf Eichmann, the Nazi official who, from his post at the head of the inscrutably named Bureau IV B 4, oversaw the grim logistics of funneling Jews into German concentration camps.

Arendt said she was struck by the fact that Eichmann was “neither perverse nor sadistic” but “terrifyingly normal.” Rather than a rabid ideologue or psychopathic anti-Semite, Arendt saw a dull bureaucrat whose zealous performance of his assigned duties was motivated largely by a desire for career advancement. “The deeds were monstrous, but the perpetrator—at least the highly effective one now on trial—was quite ordinary, commonplace, and neither demonic nor monstrous,” Arendt later wrote.

Arendt’s characterization caused much controversy. In the decades that followed, some historians have disputed her assessment of Eichmann, and philosophers have struggled with her claim that one Doing evil without being malignant.

Whatever the appropriateness of Arendt’s application of “the banality of evil” to Eichmann, it’s safe to say that the individual employees of OFAC—mostly lawyers—are not viewed as evil by those around them either. If you live near the capital, an OFAC employee might be the affable coach of your child’s soccer team or a friendly face at a community service event.

But regardless of their personalities and sincere beliefs in their commitment to public service, the harsh reality is that many OFAC employees spend their workdays carrying out the mass victimization of people who have done no harm to the United States or its citizens. To paraphrase Arendt, these people may be ordinary, but their actions are monstrous.

First, if we consider the direct and indirect effects of the invasion of Iraq, the Pentagon’s Central Command has probably caused the most harm to innocents of any organization in the world in the 21st century. However, with a staff of only 300 bureaucrats, OFAC is certainly the leader in harm per employee.

Sanctions are often seen as a welcome alternative to war. In fact, they are just another form of war — one that can also cause death and misery on a massive scale, with the vast majority of victims bearing no responsibility for the supposedly offensive actions of their governments. (While sanctions are also imposed on terrorists and drug cartels, I am focusing here on economic warfare waged against entire countries.)

The power of US sanctions stems from the dominance of the US dollar in international trade and finance. Washington Post recently explained:

“To trade in dollars, financial institutions often have to borrow, however temporarily, from U.S. counterparties and abide by U.S. government regulations. That makes the Treasury Department, which regulates the U.S. financial system, the gatekeeper to global banking activity. And sanctions are the gate.”

Sanctions come in a variety of flavors, including freezing assets, blocking financial transactions, and blocking exports or imports. There are also “secondary sanctions” aimed at non-U.S. entities that dare to do business with a sanctioned target.

Although long part of the U.S. arsenal, the use of sanctions surged in the 1990s and exploded after 9/11 with the “war on terror” and the associated increase in U.S. foreign interventionism and regime change campaigns. In 2000, there were 912 designated entities; in 2021, there were 9,421.

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Under the International Emergency Economic Powers Act of 1977, presidents have broad, unilateral authority to impose sanctions to address “an unusual and extraordinary threat” to national security. Determining what constitutes such a threat also falls to the president, and not surprisingly, they have taken a broad approach.

Sanctions can also originate in Congress. Lawmakers are eager to shore up their national security credentials and curry favor with interest groups like pro-Israel organizations, so they’re pushing them with a vengeance: In the 117th Congress, which ends in January 2023, members introduced more than 350 sanctions bills.

“It’s way, way overused and it’s gotten out of hand,” Caleb McCarry, a former staffer on the Senate Foreign Relations Committee, told the Afterwhere OFAC employees are portrayed as victims. “They are good professionals who have all this political work on their plate. They want relief from this relentless, endless, you-have-to-sanction-everyone-and-their-sister, sometimes literally, system.”

Washington’s bipartisan sanctions are undoubtedly causing OFAC employees some workplace stress and perhaps a few missed happy hours. For countless innocents in targeted countries, OFAC-enforced sanctions cause everything from unemployment, ruined career aspirations, financial insecurity and poverty to depression, hunger, disease and death.

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