The GHOST Act of 2025 (Global Hunt for Offshore Smuggling and Trafficking Act) introduces two main pillars. First, it creates the Russia Sanctions Enforcement Fund at the Treasury to pay for seizures and forfeitures connected to sanctions on Russia and “covered merchant ships” (including oil-related shipments). The fund would be administered by a DHS-appointed official and would cover a wide range of enforcement costs—law enforcement expenses, detention and disposal of seized assets, contract services, reimbursements, informants, and authorized equipment or training. It also prioritizes activities that target oil or petroleum products and other commodities used to fund evasive actions by Russia or sanctioned vessels. Second, the bill codifies the Export Enforcement Coordination Center (EECC) within Homeland Security Investigations (HSI) to serve as the federal government’s central export-enforcement hub. The EECC would coordinate across numerous agencies (State, Treasury, DoD, DOJ, Commerce, Energy, ODNI, and others), facilitate information-sharing with the intelligence community, manage enforcement actions, track and target export-control violations, and deconflict investigations. The act prescribes governance, staffing (including a Center Director from DHS/HSI and Deputy Directors from Commerce and DOJ), and a broad set of liaison roles across multiple agencies. Sponsor information shows the bill was introduced in the Senate by Ms. Ernst (with Mr. Blumenthal) and is currently introduced (not yet enacted). The overall aim is to bolster sanctions enforcement against Russia and unify export-control enforcement across federal agencies, funded in part by a new dedicated fund and overseen by annual reporting requirements.
Key Points
- 1Russia Sanctions Enforcement Fund: Establishes a Treasury fund to pay for seizures and forfeitures related to Russian sanctions and covered merchant ships, with an administrator appointed by DHS in coordination with the Treasury.
- 2Authorized expenditures: The Fund can pay for investigative costs, detention, storage, disposal, contracted services, reimbursements to agencies, informant payments, equitable sharing with other agencies, and related enforcement costs (including overtime and equipment).
- 3Priorities and additional uses: The Administrator must prioritize activities that seize oil/petroleum or other commodities used in evading sanctions; DHS may authorize additional uses such as awards for information, purchases of information, and equipment for enforcement (including joint operations with state/local agencies).
- 4Funding and repayment: Initial appropriation of $150 million for FY2026, with a plan to transfer the same amount back to the general fund by 2036; end-of-year balance limits require excess funds to be transferred to the Treasury to help pay the national debt, with inflation adjustments over time.
- 5Oversight and reporting: Annual reports (through 2036) to Congress detailing fund activity, seizures/forfeitures, financial health, transfers to the general fund, informant payments, and timelines for completing transfers.
- 6Penalties for noncompliance: If reports aren’t submitted, funds are partially transferred to the general fund; if the Fund isn’t used over a period, it can be terminated unless a Presidental waiver is granted with a congressional report.
- 7Export Enforcement Coordination Center: Establishes the EECC within HSI to coordinate export enforcement across multiple federal agencies, serve as a liaison with the intelligence community, manage information sharing, deconfliction, and integrated government-wide enforcement tracking.
- 8Governance and staffing: EECC directed by an Executive Associate Director of HSI; a Director (from the Senior Executive Service and HSI) plus two Deputy Directors (one from Commerce, one from DOJ); intelligence and agency liaisons from numerous federal departments and offices.