On Dec. 27, 2024, the Biden administration’s Treasury Department did two things, and only one of them made the news.
First, it sanctioned Bidzina Ivanishvili under Executive Order 14024 — the sanctions architecture built for the Russian Federation. In the U.S. government’s own assessment, Ivanishvili acted on behalf of — and for the benefit of — the Russian Federation while shaping Georgia’s political direction. Translate that from bureaucratese: my country’s de facto ruler works for Moscow.
Second, the Treasury issued General License 116. The license authorizes U.S. persons to continue most transactions with companies that Ivanishvili owns or controls, as long as those companies are not on the sanctions list. In practice, the individual is frozen; the corporate network around him remains largely open for American business.
EMZARI GELASHVILI: GEORGIA IS DEMOLISHING ITS WESTERN FUTURE — ONE LANDMARK AT A TIME
The man was sanctioned. The empire was licensed.
That single day captures the entire Western approach to Georgia since the Soviet collapse: symbolic clarity followed by practical accommodation. We name the problem. Then we make sure the problem can still cash the checks.
The pattern is not new
I watched the first version of this logic destroy my country in real time. In the winter of 1991-1992, I stood on Rustaveli Avenue while Tengiz Kitovani’s forces shelled the Parliament. Russian units supplied the equipment and logistics. A Russian general later put it in writing. Stability first. Georgia second. It was not phrased that plainly at the time — diplomacy rarely is.
The second time, the method changed. No tanks. No shelling of the Parliament. Just capital — and patience, which turned out to be the cheaper weapon. Ivanishvili made his fortune in Russia in the 1990s, returned home, founded Georgian Dream, served briefly as prime minister, and retired — a title that has cost him nothing and obligated him to even less. He holds no office. It has not mattered. Under his party, Georgia adopted a Russian-style foreign agents law, turned the police on its own demonstrators, and in November 2024 suspended the European Union accession process that its own constitution requires it to pursue. Georgia’s founding document did not get a vote.
The United States finally named the reality in December 2024. Then, on the same day, it undercut the naming. Call it clarity with an asterisk.
What Congress already wrote
The legislative branch has already drafted a clearer response — clearer, at least, than anything the executive branch has managed to enforce. The Mobilizing and Enhancing Georgia’s Options for Building Accountability, Resilience, and Independence Act cleared the Senate Foreign Relations Committee in March 2025 and soon after passed the House 349-42, a margin most legislation in Washington can only dream of. It has been sitting on the Senate legislative calendar ever since — more than 15 months — waiting for a floor vote that no one has scheduled, and no one appears to be in a hurry to schedule.
A second bill, the Countering China’s Control of the Caucasus Act, which requires a classified assessment of Russian and Chinese penetration of the Georgian state within 180 days of enactment, also passed the House and now waits in the Senate. Neither bill commits a single American soldier to anything. One of them commits Washington only to finding out what is already obvious. Both remain uncalled — which is its own kind of answer.
This is not legislative disagreement. It is the quietest form of the 1991 argument, updated for an age that prefers spreadsheets to shelling: better the devil with a return address than the discomfort of an actual decision.
The European version of the same reflex
Europe has followed a parallel path, with the added flourish of doing it twice. In February, it considered blacklisting the Kulevi port on Georgia’s Black Sea coast — the refining side of which, Black Sea Petroleum, is chaired by Levan Davitashvili, Georgia’s former economy minister and vice prime minister. In March, it dropped the idea after Tbilisi and the terminal’s operator promised compliance — the diplomatic equivalent of a note excusing you from gym class. The promise did not survive the semester: by June, investigators at the Organized Crime and Corruption Reporting Project’s Georgian partner iFact had documented the tanker Nephira delivering roughly 30,000 tons of Russian oil products to the port. Georgia’s own president, Salome Zourabichvili, has since said publicly that Georgian assets are being used to help finance Russia’s war — an accusation from the head of state, not a foreign critic. Only then did Brussels move against the refinery itself, with a six-month delay before the measure even takes effect. Brussels does not do urgency. It does scheduling.
Propose. Withdraw on a promise. Adopt with a head start. The choreography is consistent even when the target changes. Russia does not accept losses. It reschedules them — and it has learned, correctly, that Western capitals can usually be talked into the rescheduling.
The cost of managed decline
Georgia is not Ukraine. It is smaller, already partially occupied, and easier to treat as a secondary file. That is precisely why the pattern matters. If a country that still flies the European flag, still receives Western assistance, and still participates in NATO programs can be allowed to slide back into Moscow’s orbit while the paperwork looks orderly, then the paperwork is the point — not a byproduct of the policy, but the entire product.
I spent 12 years in Georgia’s security services working counterintelligence against Russian operations. I later served in Parliament. I know what institutional capture looks like from the inside, and I can tell you it rarely announces itself with tanks. It arrives with license numbers. The current trajectory is not improvisation. It is the logical continuation of a project that began the moment the Soviet Union collapsed. The only variable that has changed is how much discomfort Western capitals are willing to tolerate while it happens.
Right now, the answer is: very little. Sanction the individual. License the network. Pass the bills. Do not schedule the vote. Issue the statement of concern. Accept the promise of future compliance. Move on. Repeat as needed — Moscow certainly will.
What clarity would require
Clarity does not require new wars or dramatic escalations. It requires refusing to maintain the contradiction — which, admittedly, is the harder ask in this town.
If Ivanishvili is what the Treasury Department and the State Department say he is, then General License 116 should not exist in its current form. If the MEGOBARI Act and the Caucasus assessment bill are worth passing through committee and the House, they are worth a floor vote. If Georgia’s constitution still requires the pursuit of EU membership, then the suspension of that process should carry measurable consequences rather than another round of carefully worded regret. Pick one. The current arrangement — condemn on paper, cooperate in practice — is not a policy. It is a hedge.
None of these steps is radical. They are simply the difference between naming a problem and acting as if the name matters.
Governments are judged not by the sanctions they announce, but by the contradictions they choose to preserve. The contradiction is no longer hidden. The only remaining question is whether Washington intends to keep paying for the illusion that it has already condemned.
Emzari Gelashvili is a Georgian-born American analyst and former senior official in Georgia’s state security, defense, and interior ministries (1996-2008), specializing in counterintelligence against Russian operations. He served in the Georgian Parliament from 2008 to 2012.