NIKOLAS GVOSDEV: Welcome, everyone, to this latest issue of The Doorstep podcast. I'm your co-host, senior fellow at Carnegie Council Nick Gvosdev.
TATIANA SERAFIN: And I'm Tatiana Serafin, also a senior fellow at Carnegie Council.
We are so excited to welcome today Rachel Ziemba, adjunct senior fellow at the Center for a New American Security (CNAS). Her research focuses on interlinkages between economics, finance, and security issues, but she is here today with us to speak about sanctions—sanctions, sanctions, sanctions. We have big news we'll get to.
Our latest Doorsteps have focused so much on foreign policy, omnipolicy, what is Biden doing in principle and in engagement, but we really wanted to get into the nitty-gritty of how do you do foreign policy.
Certainly, sanctions is one tool—maybe?—for getting things done. I don't know. Let's talk sanctions. Are they effective? What is Biden's policy? And then we can get into some news on Nord Stream 2.
Rachel, take it away.
RACHEL ZIEMBA: Sure. Great.
I think it's great to start especially on the effectiveness issue because I think one of the things that Biden and his team have come in with—or the people I should even say Secretaries Yellen and Blinken and their teams have come in with—is a focus on trying to make things more effective.
The first thing I often end up thinking about when I think about effectiveness is: Effectiveness of what? At the end of the day these are foreign policy tools, so effectiveness should be around policy change. It shouldn't just be around can you inflict economic pain—right? We can be very good at constructing things that cause economic pain, but those sometimes can actually undermine that sort of policy change that one might be looking for.
A lot of research, academic and policy-oriented, suggests for example that central government actors or dominant players in economies linked to a military can actually end up stronger even if they're the ones sanctioned. We can look at examples like the Islamic Revolutionary Guard Corps (IRGC) in Iran for example, which has, if anything, consolidated power. We can also look at large state or state-linked entities in Russia who were some of the only ones who could gather together the foreign exchange. So in one way of looking at it you might say that that was an unintended consequence.
One of the things Biden and his team, who include a number of my former colleagues at CNAS, are really trying to think about is: How do you target this better?
Back to your question of do we have cases where sanctions have been effective in prompting policy change, the list is not long: Iran sort of in and around 2012 to sort of 2015, the Joint Comprehensive Plan of Action (JCPOA) is often an example cited; South Africa towards the end of apartheid is often cited.
There are other partial examples where the best we can say is, "Well, maybe they stopped the entity from doing more of the behavior." For example, how do we exactly interpret Russia in 2014–2015; would they have gone on to Kiev if the sanctions hadn't been imposed? There are other questions there.
But I think in all the cases that worked—or "sort of" worked—we see a dynamic not only where there is a desire to avoid and alleviate economic pain but maybe there is some upside towards compliance or a shift. For example, the Iranians thought, Not only will we avoid this damaging search situation, but maybe we can actually get access to U.S. products or European products. So I think you need both that removal of the negative and the positive.
TATIANA SERAFIN: You mentioned some examples. It's 2021. Should we be thinking of new tools? Is this kind of a relic? We talk here a lot at The Doorstep about some "relics of the Cold War" and "this is a new generation." Does our Doorstep audience care?
RACHEL ZIEMBA: I think one of the things that's most interesting about the way the Biden team came in—and a lot of the Biden team are folks who had been in the Obama administration and then spent time out of government either in think-tank-land or in the private sector—maybe more in think-tank-land—and a lot of them, people like my former colleagues Liz Rosenberg and Peter Harrell, Neil Bhatiya—a whole variety of people spent a lot of time and effort that I was privileged to be involved in trying to think about How do we use these tools more effectively?
One of the most important things is to say that we have—I think there is an understanding of How do I use restrictive tools?—I would think of them as restrictive tools—so we are cutting off access to U.S. financial bank systems; we're cutting off access, or encouraging our allies to cut off access, to certain companies doing foreign investment; we're cutting off access to goods, export controls. So you have all these restrictive elements.
We are only just starting to think about the positive side of economic statecraft. The problem is that often the positive side involves spending money, whereas the restrictive side involves cutting off access to money or resources in some way, and spending money both means that it tends to have to go through Congress, or whatever legislative body, and sometimes it involves spending money internationally, which causes all sorts of domestic politics issues.
If we look, for example, at some of the pieces of legislation that are wending their way through Congress, a number of them are saying, "Let's spend money to work with allied militaries in Association of Southeast Asian Nations (ASEAN)," for example, or "Let's spend money—"
You know, spending more money or building up resilience is sort of providing alternatives because, as I'm sure you folks at The Doorstep have been talking about, one of the big challenges when the United States goes and says, "Work with us, allies, and don't use Chinese products" or "don't interact with these entities"—maybe the argument is a little stronger with China than with entities like Iran and Venezuela—but if you go around and say, "Don't use 5G" or "Don't use Huawei 5G," what's your alternative and is it worth it if it's that much more costly?
I'm not saying that the United States and its allies are going to create an alternative to Huawei overnight, but I think thinking around what's the positive alternative, rather than just sort of, "Well, if you do this, it's dangerous for you—and oh, by the way, you might face secondary sanctions," that's where I think you see some of this balancing act.
Also, a little more strategy of trying to think about What are the core interests that the United States faces? So I think—I'm sure we'll get into the Nord Stream 2 sanctions—but one of the considerations is: What's the broader bilateral relationship with Germany? If you avoid sanctions on something, can you get interests more aligned on China policy? That's still an open question.
But the positive thing I think is also that there is a little more attempt to align with strategy. The problem is that some elements of foreign policy end up having to be reactive.
So, for example, we've seen early in the administration one of the most active sanctions programs has actually been Myanmar—or Burma as it's called in the United States—and that was really a reaction to a coup in Myanmar. We've also seen of course reaction to Russian actions.
So it's not easy to have the time to create the new strategies.
NIKOLAS GVOSDEV: Can I just jump in? As I'm listening to you discuss sanctions, and particularly the idea that it's easier to cut off, to restrict, than it is to encourage people to spend more money—but one of the things with the cutting-off aspect is it does seem that sanctions are most effective when you are cutting off goods and services to a country that wants those goods and services from us but where the United States or U.S. firms or U.S. financial institutions aren't particularly that well invested—so Myanmar, Iran, Venezuela. It's not as if there are going to be widespread layoffs on Wall Street if you impose financial sanctions on Myanmar. There may be other places where that has more of an impact.
And you've talked about the people who are on the teams. What's the sense that you have that the calibration of the punitive aspect of sanctions on other countries to try to compel or deter them from doing things, but also then trying to assess—is there a process where someone in government says, "What's the impact on Americans if we sanction?" Again, with Iran maybe we can't get carpets, we can't get pistachios; we have to get caviar, maybe we're not going to get it from Russia either, so we're going to get it—"
But I mean there's a sense that when we imposed sanctions on Iran that there wasn't a real cost for Americans, so that Americans weren't going to wake up and say, "Why can't I get Persian pistachios for my cooking today?"
Is there a sense that you have that they do try to calibrate that, that someone comes in and says, "Look, if you impose a sanction on this entity, this American company won't sell Caterpillar tractors or Ford motor vehicles and then they are going to buy from Europeans or Japanese or Chinese and that's a bad thing?" What's your sense of how that dynamic plays out?
RACHEL ZIEMBA: One of the challenges—and we jumped into it without defining financial sanctions, and what's of course interesting—so it's a whole bucket. But a lot of the things we talk about are these financial sanctions, which is the sort of arguably asymmetric use of U.S. dollar-based financial system, which of course incorporates Europe and it incorporates much of the Asian allies.
In a sense, some of the financial sanctions are a response to two problems. One is that for some of these countries like Iran—I mean the United States has had some form of sanctions on Iran for my whole lifetime, so there wasn't a lot of trade to stop directly from the United States. So this use of financial power was a way to impose a cost which the United States couldn't do via just sort of cutting off trade because it had already done that.
It was really with Iraq in the early 1990s that some of this asymmetrical use of financial power was first used, and it is often in the use of financial transactions which restrict the exports and flow of goods and access to finances from third countries. That in and of itself creates a whole set of problems.
Now, in the 2010s, when there was more of a global consensus, for example, vis-à-vis Iran, the European companies that were doing business with Iran might not have liked having to pull out, but there was a political will and consensus.
What I think was so controversial about the Trump Administration withdrawal from the JCPOA and reimposition and even greater imposition of sanctions was this political disconnect between the United States and its allies, and even its adversaries, like China and Russia, which weren't opposing sanctions to the same extent some years earlier.
In any case, this asymmetry comes into play in a few different ways, and I think what is challenging is the bigger a country you're targeting—so I think there are a different set of issues when you're talking about Russia, there's an even bigger set of issues when you talk about China, the second-largest global economy, by purchasing power parity, even bigger than that; you're looking at large domestic financial markets, and you're looking at a country that the United States does do a lot of trade with, and U.S. allies, the entities that would also need to be onboard, are also involved. Plus, at the end of the day the last thing you want is to get some sort of policy change and end up with a global recession.
I think that calibration is something that is considered in most sanctions legislation. And I should note that often sanctions have ended up as a shared responsibility. Often there might be a broad authorization that might be granted by Congress and then the administration does some of the details.
Right now we see with two key sanctions programs, Iran and Russia, there is a real tug-of-war between Congress and the administration on who gets to decide. Some of that I would say is institutional politics at work. Any legislature is always going to want to have more say and any administration is always going to want to have more freedom, unless it helps them internationally to say, "Oh, my domestic constituencies are constraining us in this way." So we can get into more of the details of that.
But I do think the issue here around allies—all of the research would say that those sanctions cases I mentioned earlier about effective cases tended to be multilateral—not always UN sort of seal of approval, but broad.
And some of the challenge with a country like Myanmar—it might not hurt the United States and U.S. consumers, but the United States doesn't trade much with Myanmar, so it doesn't actually hurt very much. So one of the debates about the Myanmar program right now is that allies that do have more trade and financial flows—like Japan, like Australia—have not been willing to join these. They're worried about will the United States step up and do secondary sanctions that might impound Myanmarese finances in their countries? Other countries that maybe would be in a different category, like Thailand, are also potentially exposed.
But I think this question of multilateral issues—one more point on multilateral that I think might be useful to put on the table is that as the United States has encouraged more allies to join them on sanctions—and not just sanctions—to beef up export controls, to beef up investment review processes, it means many more countries have some sort of process.
And for companies that already do a lot of due diligence, the last thing you want as a major company is to have a big fine. Now, maybe if your business opportunity is this big and the fine is like this big, maybe it's kind of like paying a ransom. But that's another topic that I'm sure you guys will be getting into with other people who are more expert on it than I.
For the due diligence, the compliance process for which entities are on the Specially Designated Nationals and Blocked Persons List (SDN), which are on the comparable lists for Canada, for Australia, for the United Kingdom—and the list just goes on.
There are some smaller countries that just get really stuck with what we call "de-risking." So companies or banks will just decide, "You know, it's just not worth doing business with anyone in this jurisdiction because the costs of compliance and the risks are just too high and the reward just isn't there."
TATIANA SERAFIN: I think it's so interesting what you say on multilateralism. I want to go to the topic of it works better if there are more of us agreeing on it, but it also has to work in terms of enforcement. So there is the company saying, "I'm going to comply," but who is enforcing it? If you look at—nobody is really enforcing UN sanctions; really it all falls to states or to non-state actors.
I go to a tweet of yours from today about "Is Iranian fruit coming to Canada indirectly through relabeled third countries to skirt sanctions?" Who's enforcing this? Is that a bigger problem, so that then sanctions just become rhetoric and that's why maybe the average consumer doesn't pay attention to them?
RACHEL ZIEMBA: One of the things I thought was interesting was somebody highlighted that the official Chinese data said that they had imported zero barrels of oil from Iran for the last four months. We know from good reporting and great entities like TankerTrackers and things like that—we're talking about do tools need to be reinvented.
One of the great things for those of us tracking these issues is some of the data sources have been really reinvented and reinvigorated. That helps policymakers. It also helps people like us.
There is this element of we know that China is buying Iranian crude and we know they're buying Venezuelan crude. Sometimes with countries like Iran or Venezuela, which may not have great economic data or maybe intermittent data, people like me will look and say, "What are the Chinese reporting about their bilateral trade? What are the Koreans or Turks or others reporting?"
In this case—and one of my friends is really sort of the go-to analyst on all things Iranian economy, but also more generally in West Asia, Esfandyar "Yarbatman" Batmanghelidj, came very quickly with a nice chart showing that in the same time period Chinese imports from Malaysia increased by a lot. We know, for example, Malaysia is one of the places not only where Iranian crude is transiting, but probably Venezuelan crude is transiting and being diluted with other things.
I think you're highlighting a point, which is as you have stricter and stricter sanctions—and I'll get back to who enforces in a moment—but as you have stricter and stricter sanctions, you can end up with other sort of shell companies—it's a little bit of a game of whack-a-mole from an enforcement perspective, because it pops up somewhere else—but that's why you sometimes see entities on the Office of Foreign Assets Control (OFAC) designation list—and I'll come back to who OFAC is in a moment—with many names, or sometimes a special designated national entity name will just be the name is updated.
And there can be cases of people who get mis-added to the list. There was a case earlier this year of an Italian businessman who I think owns a pizza place somewhere in Italy—I don't remember the story—who got added by mistake. He had this full legal battle to prove that he wasn't really the person who with a similar name was doing trading with Venezuela.
Back to enforcement and who's doing the enforcement. At this point, on a global level, the biggest enforcer really is the U.S. Office of Foreign Assets Control, which sits within the U.S. Treasury. It is really the enforcement arm. It manages the sanctions. If someone is in violation, they impose fines.
There can be other things that work with economic sanctions. Export control measures are done in the United States by the Department of Commerce BIS Division. For example, in the last week or so there was a settlement from goods that went to Iran some years ago with cloud computing software from a German entity that was sold to a third party in the United Arab Emirates or elsewhere, so they are now facing fines for transactions from several years ago.
But that's an interesting question on a multilateral level because few other countries have the number of people working for entities to just even track and enforce these things. Often in sanctions entities in other countries they spend some of their time thinking about entities to sanction, but they spend a lot of time just keeping tabs on what the United States is doing, both because they might want to align, but also because they want to be able to provide advice to their ministries.
And we can look at the examples of countries like Australia, Canada, and the United Kingdom, that for different reasons have either expanded or started up sanctions programs in the last few years—in the UK case, because they exited the European Union and therefore were no longer part of that overarching structure, though they did basically grandfather in all of the currently active European sanctions. But across the board, even scaled per capita, there tend to be a lot fewer bureaucrats involved and the like.
I think on the UN side you raise an important point, and that I think is not just a sanctions issue, that's a broader UN issue. At the end of the day there is this tension that I know you've talked about of how strong Member States want the United Nations to be, and legacy issues of who is in the Security Council, and so that issue is the case.
I do think when there are UN sanctions that can sometimes give a seal of approval to countries that are not Permanent Members to enforce compliance. I think you had a particular circumstance, especially with Iran and North Korea sanctions, that because there had been certain UN things that could force compliance, that they could encourage compliance, but that really came from a bilateral basis rather than for some sort of other point.
TATIANA SERAFIN: It's so interesting we keep mentioning the same countries—Russia, China, Iran, Venezuela, Myanmar. These tend to be the countries that we talk about.
And there's also issues—like narcotics trafficking and certainly the cyberwarfare—where we've seen a lot of activity coming from the administration.
I was reading something that the United States actually uses sanctions more than any other country as a tool, which I thought was interesting if we look at: is the United States still a dominant player in the world?
In your view, do you think that we still have this authority to influence with sanctions in a world that is becoming more maybe China vs. United States?
RACHEL ZIEMBA: As with so many important questions, I would say yes and no.
In a sense, there is this sort of fear factor. I think there are some interesting test cases—and Nord Stream 2 in Germany is sort of a case in point. The United States has opted to waive sanctions implementation on German entities but not on the involved Russian entities. That's part of a broader diplomatic process.
It's also part of a broader democratic political process perhaps in Germany. We know that the Greens—I'm not as versed in the exact electoral map in Germany, which is very complicated—but the Greens have a chance of providing the next chancellor and they are on the record as saying that they don't think it meets the geostrategic interests of Germany or environmental issues. They have said—I know it's easier on the campaign trail to say you'd stop something as opposed to what do you do when you're in office, and especially what do you do when you're in office if something is already built rather than you have to spend money or continue to build it. Legacy infrastructure can drive a lot of path dependence.
So I think that's an open question. You can tell from the way I'm talking about it that I'm not super-optimistic that it will go in the way that the United States is hoping.
I think the other issue goes back to the issue of restrictions versus positive—almost what are you creating? I do think that you have had a number of allies coming around and finding—if it doesn't cost too much to comply, people tend to comply. We see that with even things like trade policy, that people will pay the countries and companies will pay the fines if they're not that great but they'll fight it if it's a bigger issue.
I think it's interesting to look at what are the thematic areas where there have been more coordination in the last couple months of the Biden administration.
Around human rights and anti-corruption issues, individual sanctions, those tend to be things where there have been a number of cases where the United States has often announced sanctions at the same time as allies—like the new measures against Myanmar earlier this week—and you've also seen, for example, some coordination—not exactly at the same time—on entities involved in the poisoning and detention of Alexei Navalny.
And we've seen, for example, over the last several years a number of countries introduce programs that are aligned with what in the United States we call Global Magnitsky Sanctions, which may vary a little bit country by country. They often involve human rights restrictions, corruption, and other things, and they can actually have quite a wide scope. The European Union, for example, introduced that authority first towards the end of last year. I think on human rights issues, there maybe is a little more alignment.
But that brings up another important challenging point that I think of as something different the Biden administration is trying to put on the table compared to the Trump administration, and that's that they're trying to recalibrate sanctions to avoid exacerbating humanitarian crises.
I think if you look at a country like Iran or Venezuela or North Korea, that still have what I'd call maximum pressure sanctions, it's very difficult to have humanitarian carve-outs that work.
I also think that the Trump administration didn't try to have humanitarian carve-outs that worked, and they blocked efforts from European entities to do that, for example on Iran.
Despite all these sanctions, they are supposed to allow access to finance for needed health goods, basic supplies. I think that has sort of the de-risking point that we were talking about earlier. A lot of entities—if every bank in a country is sanctioned, as it is in Iran—a lot of entities that don't want to take that sanctions risk.
We have seen a few moves here and there to put in general licenses or sanctions waivers or exemptions for a particular type of trade, say the involvement in international humanitarian issues, say for essential things like search-and-rescue activities that might be necessary that an entity was involved in.
But I think there has probably been more talk about recalibration than has actually occurred so far. Where I'd really be watching for that is in places like Venezuela.
With Iran of course, as the negotiations go on, there is the meaningful potential for a much greater lifting of sanctions.
And then I think we see the types of entities that have been sanctioned in Myanmar reflect this. There has been a reluctance to sanction, for example, companies involved in the natural gas trade directly or to encourage third-country banks to seize those assets or make it only available—freeze those assets, apologies—well, I guess depending on your perspective freeze and seize might be quite similar.
This is an area where I think even though—and Myanmar is an interesting case that I have been working on—a number of the activists have been out in public asking for tougher secondary sectoral sanctions, I think the United States has been trying to calibrate it, partly because they want allies onboard, but they also want to be proportional.
NIKOLAS GVOSDEV: There are some points in your last answer and in the discussion that I would like to tease out a bit more and connect.
You were talking a bit about the United States and European countries increasingly applying these personalized sanctions based upon Global Magnitsky, but then we've also seen a reluctance, particularly in constituencies in London, New York, Miami, and Los Angeles about sort of blanket sanctions if it may affect the property market. We have a whole list of bad actors we want to sanction but at the same time we don't want to prevent wealthy oligarchs or semi-oligarch types from a number of countries from buying condos, that they may or may not live in—that's a separate question.
With the Nord Stream sanctions what I always thought was fascinating was the Trump administration attempted—probably very crudely but attempted—to try to do a doorstep link, which is to say, "Well, we want to sanction this pipeline so that Germany is going to buy more from American sources of energy." The Biden administration seems to have kind of downplayed that.
With the Nord Stream sanctions is there a sense that, right as Antony Blinken and Sergey Lavrov are meeting in Iceland, we announced the sanctions, we immediately waive on the Germans? Is there also a sense though that there is a sense that we are vulnerable to German actions, that the Germans might get mad and say, "All right, we're going to impose some countersanctions, and then that becomes an issue, as you said, in the trans-Atlantic relationships, and this is less about Russia or that question.
Again, there have to be limits of how far we willing to sanction if we think that there is a domestic cost—whether it's real estate developers in New York or oil and gas field workers in Montana, or even in Pennsylvania for that matter.
RACHEL ZIEMBA: Exactly. Or even the operations of U.S. or European companies abroad. So if you think about what are the interests of Total or Exxon or different things in these different jurisdictions, those sort of entities can often have quite powerful lobbying efforts, particularly if it's a jurisdiction that generally has been good for them to work in. I think you could argue that in different periods of time there were oil companies that, for example, had not been happy with their Iranian counterparts irrespective of sanctions, so there might have been more willingness to exit. But I digress.
I think there is a point about countersanctions and efforts to build resilience against U.S. countersanctions, which is something that I neglected to talk about—not because it's unimportant—but I think it's an important one because just as many countries have built up sanctions capacity, there has been a lot more talk about—in Europe they call it "strategic autonomy"—and this effort goes sort of in waves.
That's very much triggered by concerns about U.S. unilateral, extraterritorial sanctions that constrict European foreign policy—not only the issue of providing humanitarian goods to Iran or other trade that they think is legitimate to Iran, but then also Russia, which is an even bigger economic player, especially vis-à-vis Germany—they've got divergent views in the European Union about all of these issues.
One thing that we haven't mentioned is where the European Union is concerned, for EU-imposed sanctions, all the countries have to agree to lift or to put them on. That has had implications of course for the Russia sanctions. Paradoxically, it has made it easier to keep the existing ones from 2014 and 2015 in place because keeping that is easier. It's much harder to get new ones and getting any measures that address China beyond very targeted ones has been very difficult. So, there's another whole set of discussions about EU policymaking and what's done at the nation-state level versus the other. I'm sure it will come up at different points.
So far one of the challenges on the European side is having to weigh: Is it worth whatever country they're involved in versus access to U.S. markets and the like?
During the Trump Administration not only did you have these elements where European foreign policy was being encouraged because of sanctions, but you also had the Trump Administration having a very different view than past administrations about ally trade policy. For example, we had quite substantial tariffs on key goods between the United States and Europe, between the United States and Canada for that matter, the United States and its Asian allies as well. So, I think you had a dynamic where the direct interests at home in some of these allies and the foreign policy power projection and influence projection that countries were trying to do were both being impeded.
Now the Biden administration does want to work with allies, but they want to work with allies to serve what the U.S. interests are, what the United States determines the global interests are. So, I think, regardless, we have a dynamic where global rules are being rewritten and the like.
One country that we haven't talked much about from a countersanctions measure but I think is important is China. There's a whole literature, including some written by myself and colleagues, on Chinese coercive policies initiated by China but also in response to U.S. measures.
Over the last year or two China put in place what's called a blocking mechanism and other efforts that would, at least theoretically, make it illegal for Chinese businesses to comply with U.S. sanctions.
The European Union has legislation like that. It was first brought in to address the U.S. extraterritorial sanctions on Cuba and then it was updated some years ago vis-à-vis Iran. That blocking legislation basically says that European companies that lose operations solely because of U.S. sanctions are liable to some sort of compensation—it's a little vague from whom, as it always is—but also that theoretically it's illegal for them to comply.
There have not been a lot of test cases, partly because contracts are written very carefully and a lot of European countries that withdrew from countries like Iran went out of their way to say it wasn't just about sanctions, it was about operating environment, it was this, it was that. With some of these things sanctions lawyers and other lawyers are kept very busy by this.
I do think net-net—and this probably ties to some of the Doorstep issues—this whole web has the result of thickening borders. We see it at the same time as other trends to sort of deepen supply chains in major economies and continental economies. I think it just adds, as I say, compliance and due diligence costs.
I'm not spouting here corporate ideas to say there shouldn't be regulation. I'm a big believer in the right regulation. I just am aware that sometimes these sort of due diligence elements and the expectations, especially in the context where we have all those shell companies and barter trade, it becomes very difficult to operate.
And U.S. policymakers know this very well because some of this web made it very difficult, even after the JCPOA, to convince companies it was safe to go back into Iran. But that was justified. The companies' fears were clearly justified because only a few years later the United States —
But there is sort of the whole question mark of: "Well, you've suspended the sanctions, but you haven't removed them, and what's the risk profile there?" Again, it comes back to what's your upside and what's your potential downside?
TATIANA SERAFIN: Thank you so much for joining us, Rachel. We're going to leave it on "what is the upside, what is the downside" in terms of The Doorstep, and we hope to have you back as you look at the effect of Biden's sanctions policies over the next couple of months.
RACHEL ZIEMBA: Thank you.