Geoeconomics, economic sanctions, illicit finance Adj. Professor, Georgetown University Adj. Senior Fellow, @CNASdc; fmr. U.S. Treasury, White House, Congress
DC
Joined August 2008
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Thank you to @el72champs + @nytimes for including my analysis on sanctions and frozen assets in the context of ongoing U.S.-Iranian negotiations
nytimes.com/2026/05/27/world…
Alex Zerden retweeted
Over at The Sanctions Age, we've published an excellent piece by @AlexZerden on the Trump admin's efforts to "modernize" sanctions policy.
The admin has learned a few useful lessons in Syria and Venezuela, but a commitment to real reform remains lacking.
thesanctionsage.com/p/explai…
Correspondent banking is the invisible plumbing for most cross-border economic activity. With the recent U.S. economic pressure campaign against Iran, correspondent banking is back in the news as the U.S. Department of the Treasury targets financial institutions in the UAE and Turkey over the past two weeks.
Thank you to @RoryWSJ and the @WSJ for the chance to discuss the tradeoffs in using tools like OFAC economic sanctions and FinCEN Section 311 special measures (along with analysis from @ElaineDezenski):
"The question is whether U.S. banks are doing enough to ensure they aren’t clearing transactions that benefit Tehran.
It is a challenge that has long bedeviled Washington. If it enforces restrictions loosely, more transactions get through. But clamping down risks damaging the dollar’s dominance, as countries look for alternatives such as China’s yuan.
“The more you use the tools, the more you create incentives for alternatives” to the dollar, said Alex Zerden, a former Treasury official who founded financial technology and risk advisory firm Capitol Peak Strategies."
wsj.com/finance/regulation/h…
New Treasury designation today. Hitting a tiny Turkish bank ($34M in assets) for moving "tens of millions" of dollars for Iran doesn't move the needle on Operation Economic Outcast (or Economic Fury) when China processes tens of billions for the Iranian regime. home.treasury.gov/news/press…
And @USCC_GOV 2026 analysis on the tens of billions of dollar figure of Iran-China flows: uscc.gov/research/china-iran…
Alex Zerden retweeted
“And this is the challenge, also, with sanctions—that the more you use the tool, the greater you incentivize alternatives.”
Watch CNAS adjunct senior fellow @AlexZerden discuss the next phase of U.S. economic pressure against Iran on @AJEnglish.
youtube.com/watch?v=jfZN0_AH…
Alex Zerden retweeted
Rethinking Treasury's Terrorism and Financial Intelligence Office @AlexZerden #RachelLyngaas lawfaremedia.org/article/ret…
Alex Zerden retweeted
Many good, interesting ideas here from @AlexZerden and Rachel Lyngaas on how to reform some of the U.S. government's most important national security and financial crimes offices.
lawfaremedia.org/article/ret…
Originally published in the very good @TheLedgerEcon here: theledgereconstatecraft.com/…
Thank you to @lawfare for cross-posting and publishing our recommendations on essential economic national security reforms from our @TheLedgerEcon paper
Thank you to @TheLedgerEcon for publishing our paper on economic security reforms and the role of @USTreasury’s Office of Terrorism and Financial Intelligence (TFI)
Alex Zerden retweeted
Edition 3 of The Ledger: A Journal of Economic Statecraft is live.
Alex Zerden and Rachel Lyngaas argue Treasury should be the nexus of economic security efforts.
James Tennant argues the US Government is poorly organized for economic competition.
.@USTreasury OFAC enforcement action announced today against international consulting and advisory firm FTI Consulting for prohibited debt dealings with Russia's VTB Bank ofac.treasury.gov/recent-act…
Smart move by @USTreasury on the use of strategic delisting as part of sanctions modernization efforts.
Much more is needed in this space but glad to see follow-through from Sec. Bessent's speech in Paris on May 19 previewing this initiative.
I look forward to publishing a more detailed report on this and related issues over the summer.
home.treasury.gov/news/press…
Thank you @nytimes for featuring my analysis on evolving Russia and Iran sanctions policies by the U.S. Treasury Department nytimes.com/2026/05/19/busin…
Alex Zerden retweeted
“Iran will likely profit from these sales, thereby providing more money to fund its regime, the war and its proxies,” said @AlexZerden, the founder of Capitol Peak Strategies and a former official in the Treasury Department’s Office of Terrorism and Financial Intelligence. “I don’t think this stopgap measure will provide the market with assurance.”
nytimes.com/2026/03/19/us/po…
Alex Zerden retweeted
BLOOMBERG SCOOP: Sanctioned ‘Russian Gatsby’ Trust Aided by Wall Street Firms
Giftlink and thread below:
bloomberg.com/news/articles/…
Alex Zerden retweeted
Alex Zerden, a former Treasury official, said the US government historically takes so few enforcement actions that lawyers and compliance experts carefully study each one to understand the implications, particularly given the agency appears to be keeping up its focus on Kerimov.