Export Compliance

17 Saudi Nationals Sanctioned Under the Global Magnitsky Human Rights Accountability Act

The death of Saudi journalist Jamal Khashoggi sent shock waves across the globe leading several governments to condemn the incident with a number of sanctions and special investigations. In the United States, the activation of the Global Magnitsky Human Rights Accountability Act has resulted in the imposition of sanctions on 17 Saudi Arabian individuals.

All 17 individuals have been named in connection to the death of Jamal Khashoggi at the Consulate of the Kingdom of Saudi Arabia in Turkey on October 2nd, 2018. At the time the sanctions were first enforced in November, the list of individuals included members of the Saudi Royal Court and other high-ranking Government of Saudi Arabia positions.

In an official press statement regarding the sanctions, the U.S. Department of State reaffirmed its commitment to justice on the international stage.

“Our action today is an important step in responding to Khashoggi’s killing. The State Department will continue to seek all relevant facts, consult Congress, and work with other nations to hold accountable those involved in the killing of Jamal Khashoggi,” said U.S. Secretary of State Michael R. Pompeo.

What Is The Magnitsky Act?

 The Global Magnitsky Act is the latest in a series of laws named after Russian whistleblower Sergei Magnitsky, who died while in detention in Russia. The first of the Magnitsky laws, formally known as the Sergei Magnitsky Rule of Law Accountability Act, was first enacted in 2012. The law then mandated that State and Treasury departments could impose various sanctions on any individuals who are deemed to have committed gross violations of human rights in Russia.

 The second of the Magnitsky laws, the Global Magnitsky Act, extends these provisions to include human rights violations anywhere on the globe. Unlike the first act, the Global Magnitsky Act gives the president the discretion to determine the appropriate sanctions to impose.

 Why This Matters to Exporters

The recent sanctions by the U.S. State Department reflect an increased propensity for western governments to react to crimes and human rights violations committed across the globe. Sanctions like those applied under the Global Magnitsky Act are becoming more common. Companies must be proactive in recognizing offending actors and avoid them at all costs.

A notable example of this includes the U.S. Commerce Department’s decision to impose sanctions on Chinese chipmaker Fujian Jinhua Integrated Circuit Co. in late October. According to a statement released by the department, the company “poses a significant risk of becoming involved in activities that are contrary to the national security interests of the United States.”

In this new era of international enforcement, it’s important for companies to do proper due diligence and verify they’ve chosen to conduct business with the right individuals, organizations, and countries, especially when the reputation of your business depends on it.


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