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  • Writer's pictureInternational Lawyers Project

A Journey of 20: An Empirical Study of the Impact of Magnitsky Corruption Sanctions

The International Lawyers Project (ILP), in partnership with Anton Moiseienko from the Australian National University, conducted an empirical study of the impact of the U.S. anti-corruption sanctions. This sanctions impact research is the first-of-its-kind in providing findings and recommendations that will add to the policymakers’ understanding of what Magnitsky-style corruption sanctions can and do achieve based on empirical evidence.

In particular, the research project reviewed the earliest corruption-related designees under the Global Magnitsky Program:


Home Jurisdiction

(where the targeted individual’s activities have primarily taken place, as identified based on the case study analysis)

Date of Sanctions

Felix Ramon Bautista Rosario

​Dominican Republic

21 December 2017

Benjamin Bol Mel

​South Sudan

21 December 2017

Artem Chayka


21 December 2017

Dan Gertler

Israel & The Democratic Republic of Congo

21 December 2017

Yahya Jammeh

The Gambia

21 December 2017

Gulnara Karimova


21 December 2017

Roberto Jose Rivas Reyes


21 December 2017

Angel Rondon Rijo

Dominican Republic

21 December 2017

Slobodan Tesic


21 December 2017

Jose Francisco Lopez Centeno


5 July 2018

Roberto Sandoval Castaneda


17 May 2019

Ahmed Al-Jubouri


18 July 2019

Nawfal Hamnadi Al-Sultan


18 July 2019

Ajay, Atul, and Rajesh Gupta

India & South Africa

10 October 2019

Salim Essa

South Africa

10 October 2019

Ashraf Seed Ahmed Al-Cardinal

South Sudan

​11 October 2019

Kur Ajing Atern

South Sudan

11 October 2019

Kharmis Farnan Al-Khanjar Al-Issawi (aka Al-Khanjar)


6 December 2019

The report highlights the following key recommendations:

  1. Governments should not assess the effectiveness of sanctions purely in terms of measurable outcomes, such as the amount of assets frozen. However, they should conduct regular reviews of the impact of their sanctions, even though such a review will of necessity involve imprecise, subjective assessments.

  2. Governments should seek to identify and publicise corporate networks associated with targeted individuals.

  3. In determining appropriate targets for Global Magnitsky sanctions, governments should prioritise individuals who rely on the international financial system and therefore are more likely to be affected by the designation.

  4. In imposing Global Magnitsky sanctions on those whose wrongdoing has been addressed by domestic justice systems, governments should develop a clear understanding of the added value that the designation would have in the circumstances.

The report will be launched in London on Thursday 29th June 2023 from 10am BST. The launch event will include a roundtable with sanctions experts speaking on The Opportunity Magnitsky Style Sanctions Present in the Global Fight Against Corruption. To join virtually, please register here.

More than five years following its enactment, the United States Government has designated around 450 foreign persons and entities from around the world for human rights and corruption abuses under its Global Magnitsky Program. Through Executive Order 13818, the Global Magnitsky Act has expanded the scope of sanctionable targets to include wider networks of individuals and entities to implement the most comprehensive targeted human rights and anti-corruption sanctions law in its history.

The use of targeted sanctions against corrupt public officials, entrepreneurs, and professional enablers is a relatively novel and promising approach to fighting corruption, but only a few regimes – i.e., the U.S., the United Kingdom, Canada, and Australia, have established their own Magnitsky-style corruption-related sanctions.

Geographically, sanctions designations span several jurisdictions on a global scale, where targeted individuals included government and military officials, as well as private citizens.

To download a copy of the report please see below:

Sanctions Research Report
Download • 775KB


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