Federal agencies must cross-check sanctions lists within 90 days
H.R. 4291 — Sanctions Lists Harmonization Act · Filed by Randy Fine (R-FL) · 9 cosponsors · Introduced Jul 2, 2025 · Reported out
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What it does
This bill requires federal agencies that maintain sanctions lists (Treasury's OFAC lists, Commerce's export controls, and Defense's military-industrial complex list) to notify each other within 30 days when someone is added to any one list, then review and decide within 90 days whether that person should also be added to the other lists. Agencies must report annually to Congress on compliance and any new additions resulting from this cross-list review process.
Why we flagged it
The bill's core function is procedural: it mandates inter-agency notification and review protocols to harmonize existing sanctions lists. It does not create new sanctions, expand the scope of sanctionable conduct, or establish new authorities—it coordinates existing ones.
What the text implies
- Accelerated cross-listing may result in individuals/entities appearing on multiple sanctions lists simultaneously without separate substantive review for each list's distinct legal standard or evidentiary threshold.
- The 90-day determination window is mandatory but outcome-neutral—agencies must decide but are not required to add anyone; however, the notification-and-review pipeline may create institutional pressure to harmonize.
- Annual reporting requirement is unclassified but may contain classified annexes, limiting public visibility into which entities were added and why.
- No explicit appeal, delisting, or due-process mechanism is created by this bill; it operates within existing sanctions frameworks, which vary in procedural protections.
Section numbers refer to the bill text the analysis read — linked under Primary records below.
Who it affects
The bill improves government coordination and transparency in sanctions enforcement, which benefits citizens by closing gaps that bad actors might exploit. However, the bill creates no new substantive rights for citizens and may accelerate inclusion on multiple lists without additional due-process safeguards, potentially affecting innocent parties caught in broad sanctions nets.
Named in the bill
Office of Foreign Assets Control (OFAC), Department of Treasury, Department of Commerce, Bureau of Industry and Security, Department of Defense, Export Administration Regulations, Specially Designated Nationals and Blocked Persons List, Entity List, Non-SDN Chinese Military-Industrial Complex Companies List, Sectoral Sanctions List, Military End User List
Where it stands
9 cosponsors: 8 Republicans, 1 Democrats.
- Jul 2, 2025 — Introduced · Congress.gov: “Introduced in House”
- Jul 2, 2025 — Referred to House Committee on Armed Services and House Committee on Foreign Affairs · Congress.gov: “Referred to the Committee on Foreign Affairs, and in addition to the Committee on Armed Services, for a…”
- Dec 3, 2025 — Markup held in committee · Congress.gov: “Committee Consideration and Mark-up Session Held”
- Dec 3, 2025 — Reported out of committee · Congress.gov: “Ordered to be Reported by the Yeas and Nays: 49 - 0”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
2 lobbying clients named this bill on 2 disclosure filings across 1 quarter, Dec 2025 to Dec 2025. Those filings disclosed $1,263,910 in lobbying spend. A filing names 60 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 41% of bills with at least one filing.
Randy Fine, the sponsor, reported $439,660 in PAC receipts in the 2026 cycle.
- American Israel Public Affairs Committee — $973,910 on 1 filing
- Fdd Action — $290,000 on 1 filing
Lobbying Disclosure Act filings through Jan 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the bill text published by Congress.gov (3,631 characters) on Jun 3, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Dec 2025. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jan 20, 2026 · page rendered 2026-10-20.
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