First appearing in 1999, the U.S. Department of State maintains a Countries of Particular Concern (CPC) list that names countries for either engaging in or tolerating ongoing severe violations of religious freedom. There is also an Entities of Particular Concern (EPC) category intended for groups, such as ISIS, which severely violate religious freedom but do not comprise a sovereign state.  

Since 2016, there has been a Special Watch List (SWL) category for countries that have ongoing violations of religious freedom, but not quite to the extent of a CPC.  

Normally, this list is updated each year at some point between September and the end of December. But if you visit the State Department’s website, you will notice that it hasn’t been updated since Dec. 29, 2023.  

The U.S. Commission on International Religious Freedom (USCIRF) released a 2024 report recommending countries for the list, but evidently, no ensuing CPC designations were made that year.  

One reason for the delay could be the change of presidential administrations.  

“New administrations often review policy tools and may adjust processes, criteria, or timing,” said Prof. Ronald Rychlak of The University of Mississippi School of Law. 

Even though the USCIRF has already released its 2025 report with recommended CPC list countries, the State Department “may be waiting for its own internal review or for more corroboration before acting,” Rychlak said.  

During an “internal review,” State Department staff would consider such aspects as political and strategic relationships.  

“The State Department may decide that engaging with a particular country first, rather than formal designation, is a more effective way to deal with it,” Rychlak said. “Or there may be concerns about retaliation, or other diplomatic fallout.” 

Once a country receives CPC designation, the U.S. government has 15 possible choices of punishments ranging from “lighter diplomatic measures to heavy economic sanctions,” Rychlak explained. 

Officially, the U.S. government must inflict a punishment that is equivalent to the severity of the religious freedom violations that earned the designation.  

“Lighter” measures would include something like canceling official visits, while heavier measures could include withholding development aid, imposing trade sanctions, or even freezing assets. The U.S. might also withdraw security assistance or prohibit any U.S. financial institution from making significant loans to that country.  

In special cases with pariah states like Iran and North Korea, they already face heavy sanctions. So there really isn’t much more one can punish them in that regard.  

Technically, the U.S. government is required to “take some form of action in response to a CPC designation,” Rychlak said. But the U.S. government also reserves the right to waive sanctions due to various reasons. And so, waivers are given often, perhaps a bit too often.  

For example, waivers have been given to Pakistan and Saudi Arabia, among other countries, for reasons that are in the “important national interest of the United States.” 

Also, with some ex-Soviet countries in Central Asia, the U.S. government has perhaps been a bit lenient on violations of religious freedom in return for those governments getting more proactive about fighting their region’s narcotics trade.  

Even if the U.S. refuses to give a waiver, there are limits to the power of its sanctions. For example, “the U.S. by itself could not stop leaders from traveling to other countries,” Rychlak said. “The nations of the world could, however, do something with the International Criminal Court, if violations were to get that extreme.” 

Even on its own, though, a CPC designation is supposed to have value in that it carries international stigma. But some countries are so far into pariah status that they are likely immune to such stigma.  

However, some foreign governments do indeed take the CPC designation seriously. After all, “CPC status can stigmatize a country and influence other governments, international organizations, and private actors to scrutinize or pressure the offending country,” Rychlak said. “It can also affect negotiations, military aid, and international partnerships.” 

Though in theory the U.S. Commission on International Religious Freedom (USCIRF) report is supposed to influence the ensuing CPC list, the State Department often sees things quite differently than the USCIRF about which countries are suitable selections. In fact, the USCIRF was so dissatisfied with the last CPC list — which failed to include Nigeria and India — that it called for a congressional hearing. 

Citing the congressional hearing, Rychlak said he expects at least Nigeria to appear on the next CPC list. 

In 2020, Nigeria — the world’s leading site of religiously-motivated Christian bloodshed — finally received designation as a CPC, only to have it stripped the following year. Meanwhile, India, amid deteriorating religious freedom conditions in recent years, has eluded CPC designation.  

With a different presidential administration this year, there are likely significant CPC changes coming in the near future.  

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