Overview
UK Sanctions
The UK introduced its global anti-corruption sanctions regime in April 2021 under the Global Anti-Corruption Sanctions Regulations 2021, which enables the UK to impose asset freezes and travel bans on individuals and entities involved in bribery or misappropriation of property.
Pursuant to the 2021 Regulations, bribery occurs where a person offers an advantage to a foreign public official and the person intends to induce that official to perform improperly a public function, or a foreign public official requests or accepts advantages and that official intends to improperly perform a public function.
US Sanctions
The US imposes corruption-related sanctions under its Global Magnitsky regime. In December 2017 pursuant to EO 13818, President Trump introduced sanctions on persons involved in corruption (as well as serious human rights abuse). Corruption includes the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery.
Current UK Sanctions
The UK introduced its global anti-corruption sanctions regime in April 2021 under the Global Anti-Corruption Sanctions Regulations 2021, which enables the UK to impose asset freezes and travel bans on individuals and entities involved in bribery or misappropriation of property.
Pursuant to the 2021 Regulations, bribery occurs where a person offers an advantage to a foreign public official and the person intends to induce that official to perform improperly a public function, or a foreign public official requests or accepts advantages and that official intends to improperly perform a public function.
Current US Sanctions
The US imposes corruption-related sanctions under its Global Magnitsky regime. In December 2017 pursuant to EO 13818, President Trump introduced sanctions on persons involved in corruption (as well as serious human rights abuse). Corruption includes the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery.
- Legislation
31 CFR Part 583 – Global Magnitsky Sanctions Regulations
EO 13818 Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption (Effective Date – December 21, 2017)
Global Magnitsky Human Rights Accountability Act 22 U.S.C. 2656 note – Public Law 114-328
- Sanctions List
Search GLOMAG Program on the OFAC SDN List
- Guidance
- US General Licences
Global Magnitsky General License 3 – Authorizing Transactions Related to Debt or Equity of Pingtan Marine Enterprise Ltd. (December 09, 2022)
Global Magnitsky General License 4 – Authorizing the Wind Down of Transactions Involving Certain Vessels (December 09, 2022)
Global Magnitsky General License 5 – Authorizing Certain Transactions Related to Frigorifico Chajha S.A.E. (January 26, 2023)
Global Magnitsky General License 6 – Authorizing the Wind Down of Transactions Involving Bebidas USA Inc., Tabacos USA Inc., Frigorifico Chajha S.A.E., Dominicana Acquisition S.A., or Certain Blocked Entities Owned by Horacio Manuel Cartes Jara (January 26, 2023)
Global Magnitsky General License 7 – Authorizing Certain Transactions Involving Tabacalera del Este S.A. or Tabacos USA Inc. Pursuant to the Tobacco Master Settlement Agreement (March 31, 2023)
- Judgments
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Rahmani v Janet Yellen Civil Action No: 24-0285 (RC)
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