Exploring the consequences of corruption-related sanctions under the U.S. Global Magnitsky Program (Glo Mag), eighteen case studies starting with the earliest designations in December 2017 have been analysed to explore the impact of sanctions, more than five years from enactment. While comprising only a relative minority, the following eighteen designees hail from all the regions that feature in later designations, except for East Asia and the Pacific, which are indicative of geographical and regional representation of corruption sanctions:
Highlighting the findings relative to the forms of impact that sanctions can produce, publicly-available and open-based research on the designees’ affiliated companies and corporate networks were of crucial note, as well as the relevant relationship between the U.S. Global Magnitsky sanctions, prior domestic action in the targeted individual’s home jurisdiction, and subsequent non-U.S. sanctions, among others. In more detail, close scrutiny of the eighteen case studies yielded the following forms of impact:
Notable conclusions from the empirical study of the eighteen case studies include the following:
Actual freezing of assets is the most widespread effect of sanctions in the sample analysed, but their enforcement relies on the availability of information about the targeted individual’s corporate network;
In a third of the case studies analysed, no discernible impact on the targeted individual was observed beyond media scrutiny, which is a given.
Half of the case studies analysed involved prior domestic action, such as investigations or criminal convictions; and
More than a third of the case studies analysed involved subsequent sanctions designations by other countries, in all instances the UK.
The case studies supplement the International Lawyers Project and Australian National University’s collaborative report examining the aftermath of the earliest corruption-related sanctions designations under the U.S. Global Magnitsky Program entitled, ‘A Journey of 20: An Empirical Study of the Impact of Magnitsky Sanctions on the Earliest Corruption Designees’. Following successive launches in London, United Kingdom and Canberra, Australia in June 2023, the report’s key recommendations on Magnitsky-style sanctions were presented before policymakers, government officials, and relevant stakeholders.
The full copy of the report and the case studies are accessible here: