OFAC Publishes Global Magnitsky Sanctions Rules
The Treasury Department's Office of Foreign Assets Control has published new regulations implementing the Global Magnitsky Act, detailing prohibitions and exemptions for dealings with persons involved in human rights abuse or corruption.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) has published regulations to implement the Global Magnitsky Human Rights Accountability Act and Executive Order 13818. The rules, codified at 31 C.F.R. Part 583, formalize and detail the U.S. sanctions regime targeting foreign persons designated for involvement in serious human rights abuse or significant corruption. These individuals and entities are added to OFAC's Specially Designated Nationals (SDN) List under the identifier “[GLOMAG],” effectively blocking their property and prohibiting U.S. persons from transacting with them.
For global businesses and financial institutions, these regulations heighten the importance of robust sanctions-compliance and third-party due diligence programs. The rules clarify the scope of prohibited activities and provide key definitions, such as what constitutes "financial, material, or technological support." They also outline specific exemptions for personal communications and certain informational materials, although some software-related transactions remain prohibited. Counsel should immediately integrate these specific regulations and the GLOMAG identifier into their compliance frameworks and advise clients on the heightened risks associated with international dealings. The initial release indicates that more comprehensive regulations are expected to follow.