Global Magnitsky Act and EO 13818 (2016, 2017)

The Global Magnitsky Human Rights Accountability Act and Executive Order 13818 provide related but distinct United States authorities concerning serious human-rights abuse and corruption. The executive order's criteria and blocking architecture are broader in important respects than the statute alone.

Separate authorities

The statute authorises specified property and visa measures against qualifying foreign persons. Executive Order 13818, issued under the International Emergency Economic Powers Act (1977) and other authority, declares a national emergency and establishes blocking criteria for persons connected to serious abuse or corruption.

Treasury designations block property and interests in property within US jurisdiction and generally prohibit dealings by US persons, subject to licences. State visa restrictions use separate authorities and need not create an OFAC blocking consequence. Editors should identify the department, authority and measure in each case.

The programme differs from the country-focused Sergei Magnitsky Rule of Law Accountability Act (2012). A person on the Specially Designated Nationals and Blocked Persons List may carry several tags, but list placement does not merge their legal bases.

Evidence and process

Designation announcements state the government's findings and attributed factual basis. They are administrative acts, not criminal judgments. Current status, aliases, related entities, licences and delisting must be checked through OFAC's sanctions-list service.

Targets can seek administrative reconsideration and judicial review under applicable law. Public evidence, classified information and procedural standards may differ from a criminal case. Copy should therefore preserve the authority's attribution and avoid restating allegations as adjudicated facts.

Statecraft assessment

The programme can restrict dollar access, deter counterparties and signal norms. It can also produce over-compliance or substitution. A designation count does not measure asset value, behavioural change or deterrence, and historical totals quickly become stale.

Other jurisdictions have adopted Magnitsky-style authorities, including the United Kingdom under regulations made through the Sanctions and Anti-Money Laundering Act (UK, 2018). Similar naming does not make the legal tests, lists or due-process routes identical.

As at 30 July 2026, current OFAC list data control designation status. Claims of diffusion, democratic alignment or behavioural effect should be attributed analysis with a defined comparison.

Designation analysis

Each case should identify the exact executive-order criterion, designated person, conduct, supporting entity relationship and effective date. A corruption designation can concern misappropriation, bribery or support under specified language; it should not be restated as a criminal conviction unless a court has decided that issue.

Ownership rules can extend blocking consequences to entities owned at the relevant threshold even when they are not separately named. Control without ownership may present compliance risk but should not be stated as automatic blocked status under an ownership rule.

State visa announcements can be public or confidential depending on authority. Absence of a public visa notice does not prove that no restriction exists, and an OFAC listing does not itself establish a visa consequence.

Evaluation should distinguish assets identified, transactions blocked, counterparties withdrawing, official behaviour changing and public signalling. These outcomes require different sources. The programme's continued use establishes policy activity, not a settled estimate of deterrence.

Sources

1. US Treasury, current Global Magnitsky sanctions programme (accessed 30 July 2026).
2. US Treasury, OFAC executive-order library (accessed 30 July 2026).
3. US Treasury, Global Magnitsky Human Rights Accountability Act text.
4. US Treasury, OFAC sanctions-list service (accessed 30 July 2026).