On December 20, 2017, President Trump signed Executive Order (“Order”) 13818 titled “Blocking the Property of Persons Involved in Serious Human Rights Abuses or Corruption”.  The Order implements the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”), which was signed into law on December 23, 2016 and which targets human rights abusers and corrupt actors globally.  This is to be contrasted with the Sergei Magnitsky Rule of Law Accountability Act of 2012 (“Magnitsky Act”) targeting human rights abusers in Russia, with respect to which the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published regulations on December 21, 2017.  In addition, OFAC designated a number of individuals and entities as Specially Designated Nationals (“SDNs”) under the Magnitsky Act on December 20, 2017 and under the Global Magnitsky Act on December 21, 2017.

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