In 2023, sanctions continued to be a popular tool of foreign policy and many new individuals and entities were designated for one reason or another. As CiFAR launches its updated Sanctions Watch platform today, which tracks individuals sanctioned for reasons related to corruption, this blog takes stock of the changed listings across key anti-corruption sanctions regimes in 2023.
US Global Magnitsky regime
The United States continues to be the most active sanctioning jurisdiction, coordinating its designations with other countries and utilising various sanctions regimes. It has utilised its anti-corruption sanctions under the Global Magnitsky Human Rights Accountability Act to designate 11 individuals this year. Similarly, the year before, in 2022, the US added 12 persons to its Global Magnitsky list for reasons relating to corruption or corruption and human rights violations.
The 2023 designations concerned political figures from Paraguay, several current or former Bulgarian government officials, a politically exposed person from Haiti, and one Guatemalan individual accused of engagement in bribery schemes, including in government procurement of Sputnik V COVID-19 vaccines. Additionally, two businessmen and political figures from Afghanistan were sanctioned for their alleged involvement in complex procurement corruption schemes on U.S. government contracts.
As of the start of January 2024, according to CiFAR’s analysis, the US Global Magnitsky regime (GLOMAG) entails 108 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 the plans to follow the practice of its partner sanctioning jurisdictions and adopt an EU global sanctions regime for corruption have been underway in 2023, they have yet to materialise. 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.
However, none of these regimes saw any changes in 2023. This means that 35 out of 48 initially sanctioned people remain sanctioned in relation to Tunisia, and 3 persons out of 22 initially sanctioned remain on the list of Ukraine misappropriation sanctions.
The Egypt regime was lifted in 2021.
Canadian anti-corruption sanctions
Canada designated Lebanon’s former Central Bank Governor Riad Salameh and his associates. In contrast to the UK, which sanctioned 4 individuals related to this case, Canada sanctioned only three. In total, from the 80 designated persons targeted by the Victims of Corrupt Foreign Officials Act – the Canadian version of the Magnitsky legislation. 55 of them are targeted due to corruption or corruption and human rights. (Canadian designations do not clearly distinguish between human rights or corruption designation.)
Canada also imposed sanctions after the Arab Spring and Ukrainian Maidan revolutions. None of these regimes have seen any changes this year. Therefore, as of December 2023, there were 24 people sanctioned under the Freezing Assets of Corrupt Foreign Officials Act, either from Ukraine or Tunisia.
UK Global Anti-Corruption Sanctions Regulations
The United Kingdom expanded its anti-corruption sanctions list twice in 2023. First time it targeted 3 influential Bulgarian individuals allegedly involved in corruption in Bulgaria, who were already sanctioned under the US Magnitsky legislation. Second time the UK also coordinated with its partners in the US and Canada and designated Lebanon’s former Central Bank Governor Riad Salameh and his three associates. This brought the number of individuals sanctioned for corruption by the UK to 39.
Swiss anti-corruption sanctions (asset freezing orders)
A special administrative legal regime allows the Swiss government to apply asset freezing orders via the Foreign Illicit Assets Act (FIAA) in cases involving politically exposed persons (PEPs) very quickly. After several delistings, eight people remained on the list in Switzerland at the start of 2023. However, after May 2022, Switzerland commenced several confiscation proceedings concerning these assets (some linked to Yuriy Ivanyushchenko), totaling about EUR 139 million (CHF 130 million). According to the Swiss government, the commencement of confiscation proceedings has obviated the need for the asset freeze, and the 2014 Ordinance in connection with Ukrainian assets was terminated on 27 February 2023. Therefore, at the end of 2023, there were 0 persons subject to Swiss asset freezing orders linked to the misappropriation of state assets.
Table: Changes in individual listings in key anti-corruption sanctions regimes in 2023
| Regime | Removals | Additions | Total corruption designations in Dec 2023 |
| US Global Magnitsky Human Rights Accountability Act | 0 | 11 | 108 |
| UK Global Anti-Corruption Sanctions Regulations | 0 | 7 | 39 |
| EU misappropriation sanctions Tunisia | 0 | 0 | 35 |
| EU misappropriation sanctions Ukraine | 0 | 0 | 3 |
| Canadian Freezing Assets of Corrupt Foreign Officials Act | 0 | 0 | 24 |
| Canadian Justice for Victims of Corrupt Foreign Officials Act | 0 | 3 | 55 |
| Swiss Foreign Illicit Assets Act (Ukraine) | 8 | 0 | 0 |
| Total all regimes | 8 | 21 | 264* |
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, the UK, and the 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 every six months. To see the individuals sanctioned for their alleged involvement in corruption or to download the complete database, please visit Sanctions Watch.
For a summary of changes in 2022, see our previous blog here.