On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act (Global Magnitsky Act). The Global Magnitsky Act allows the U.S. government to target persons and entities involved in gross human rights abuses – such as torture and extrajudicial killings – and government officials their senior associates involved in significant acts of corruption.

The day after E.O. 13818 was signed, the Office of Foreign Assets Control (OFAC) added 52 individuals and entities to the Specially Designated Nationals (SDN) List pursuant to the new authority, effectively blacklisting those parties, cutting them off from the U.S. financial system, and barring their entry into the United States. U.S. persons and companies must freeze listed parties’ assets and are prohibited from conducting further direct or indirect transactions involving the listed parties.

While Russian persons were designated as SDNs under the Global Magnitsky Act in December, the law is distinct from and broader than the original Magnitsky Act, which specifically targets Russian officials involved in the arrest, torture, and death of Sergei Magnitsky, a Russian lawyer who exposed a corruption scheme involving the Russian government.