While sanctions lists have grown this year primarily due to new listings in connection to individuals linked to Russia’s invasion of Ukraine, anti-corruption sanctions have not been forgotten. As CiFAR launches its updated Sanctions Watch platform today, which tracks individuals sanctioned for reasons related to corruption, this blog takes stock of this year’s changes in key anti-corruption sanctions lists across different jurisdictions.
US Global Magnitsky regime
The United States remained the most active in imposing anti-corruption sanctions this year, undertaken under its Global Magnitsky Human Rights Accountability Act. It added 12 persons to its Global Magnitsky list for reasons relating to corruption or corruption and human rights violations. Notably, the US sanctioned individuals alleged to be involved in corruption in Liberia, Moldova, El Salvador, Mali, and corruption in Guatemala, repeatedly. As of December 2022, the US Global Magnitsky regime (GLOMAG) entails 91 persons listed for reasons related to corruption. Legal entities which are linked to these individuals are at times sanctioned as well.
European Union misappropriation sanctions
Even though Ursula von der Leyen announced the plans to expand the EU’s existing human rights sanctions regime, corruption as an offence that could trigger the imposition of the EU’s restrictive measures has yet to be included. Therefore, at the moment, the only regimes with an anti-corruption focus are the EU misappropriation sanctions, adopted after the 2011 revolutions in Tunisia and Egypt and 2014 in Ukraine on people suspected of corruption from the ousted regimes.
In 2022, initially one, and then another seven people were deleted from the Tunisia list, which means that 35 out of 48 initially sanctioned people remain sanctioned.
Three persons out of 22 initially sanctioned remain on the list of Ukraine misappropriation sanctions, after five persons were deleted this year: Oleksandr Klymenko, and later Viktor Yanukovych and Viktor Pshonka with their sons. However, former President Yanukovych and his son are now designated in the EU’s Russia sanctions regime.
The Egypt regime was lifted in 2021.
Canadian anti-corruption sanctions
Canada also imposed sanctions after the Arab Spring and Ukrainian Maidan revolutions, as well as implemented its own version of the Magnitsky legislation via the Justice for Victims of Corrupt Foreign Officials Act. None of these regimes saw any changes this year. Therefore, as of December 2022, there were 24 people sanctioned under the Freezing Assets of Corrupt Foreign Officials Act, either from Ukraine or Tunisia. From the 70 designated persons targeted by the Victims of Corrupt Foreign Officials Act, 52 of them are targeted due to corruption and/or human rights. (Canadian designations do not make the designation reason clear to distinguish between human rights or corruption designation.)
UK Global Anti-Corruption Sanctions Regulations
The United Kingdom expanded its anti-corruption sanctions list this year only once, on International Anti-Corruption Day on 9th December. It designated five individuals, four of which were already targeted in the US by the Magnitsky Human Rights Accountability Act. Additionally, the UK also sanctioned Ilan Shor due to his alleged involvement in the Moldovan Billion Dollar Bank Fraud Scandal. Shor is also sanctioned in the US but for reasons of his alleged interference in Moldovan elections for the benefit of Russia. Therefore, he appears on the Russia EO14024 sanctions list, not under the Global Magnitsky designations.
Swiss anti-corruption sanctions
After several delistings made last year, Switzerland’s Ukraine regime remained intact this year, with eight people currently on the list until its renewal at the end of February 2022. This is Switzerland’s last remaining sanctions regime linked to popular uprisings in the Arab Spring countries and Ukraine.
Table: Changes in individual listings in key anti-corruption sanctions regimes in 2022
| Regime | Removals | Additions | Total designations in Dec 2022 |
| US Global Magnitsky Human Rights Accountability Act | 0 | 12 | 97 |
| UK Global Anti-Corruption Sanctions Regulations | 0 | 5 | 32 |
| EU misappropriation sanctions Tunisia | 8 | 0 | 35 |
| EU misappropriation sanctions Ukraine | 5 | 0 | 3 |
| Canadian Freezing Assets of Corrupt Foreign Officials Act | 0 | 0 | 24 |
| Canadian Justice for Victims of Corrupt Foreign Officials Act | 0 | 0 | 52 |
| Swiss Foreign Illicit Assets Act (Ukraine) | 0 | 0 | 8 |
| Total all regimes | 13 | 17 | 251* |
Sanctions Watch
Sanctions Watch, a one-of-a-kind resource on anti-corruption sanctions, tracks individuals sanctioned in response to serious corruption allegations under key anti-corruption regimes worldwide, including Canada, the European Union, Switzerland, UK, and United States.
Sanctions Watch allows people to search for and find information on individuals sanctioned for corruption by name, country, as well as sanction regime. Besides profiles of each sanctioned individual, the platform also offers analysis and resources about each anti-corruption sanctions regime, as well as compliance guidelines for the private sector, and our research in different countries about anti-corruption sanctions.
CiFAR updates the website and database on which it is based on every six months. To see the individuals sanctioned for their alleged involvement in corruption or to download the complete database, please visit Sanctions Watch.
This blog was edited in 2023 to include additional listings that were made made at the end of 2022