On December 10, the U.S. Treasury Department announced sanctions against 18 individuals and three entities under the Global Magnitsky Human Rights Accountability Act, which targets alleged perpetrators of serious human rights abuses and corruption. The newly listed individuals and entities are from Slovakia, Burma, Libya, Democratic Republic of Congo, Pakistan, and South Sudan. Almost two years after President Trump issued an executive order implementing the Global Magnitsky Human Rights Accountability Act, there are now 196 individuals and entities sanctioned under it.
The individuals and entities sanctioned under the Global Magnitsky program are from a wide variety of countries, some relatively predictable (like Iraq and Russia) and others much less so (like Canada and the Netherlands). Other countries whose residents have been sanctioned under the program include: the British Virgin Islands, Cambodia, China, Cyprus, the Dominican Republic, Gibraltar, Guatemala, Hong Kong, Israel, Latvia, Mexico, Nicaragua, Saudi Arabia, Serbia, South Africa, The Gambia, and Uzbekistan. The growth of the Global Magnitsky program means the likelihood of dealing with a Specially Designated National (SDN) continues to increase, and not just for obvious countries like Iran, Cuba, and North Korea. This further highlights the importance of having effective denied party screening procedures for counterparties.
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