
2024 has seen an acceleration of targeted anti-corruption listings, with 32 new individuals being sanctioned, proving once again the use of targeted sanctions as a powerful diplomatic and anti-corruption tool. 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 2024.
US Global Magnitsky regime
Continuing to lead as the most active sanctioning jurisdiction, the United States sanctioned 18 additional individuals for corruption or corruption and human rights violations in 2024, under the Global Magnitsky Human Rights Accountability Act. It also coordinated its designations with other countries and sanction regimes, especially the UK. This can be compared to 2023when the US added 11 individuals for corruption-related activities to its Global Magnitsky list.
The 2024 designations included a Guatemalan political figure accused of abusing his position at the Ministry of Energy for personal gain, the current president of Zimbabwe, Emmerson Mnangagwa – following the suppression of the sanctions regime specifically designed for Zimbabwe -, along with the First Lady and two other Zimbabwean nationals in relation to oil deals, 3 individuals from Guyana for their alleged implication into tax fraud, and finally 9 individuals related to a global network of companies supposedly designed to hide corrupt profits from gold and diamond smuggling, and revolving around the figure of Kamlesh Pattni. This action has been undertaken in coordination with the UK, which designated 3 of these persons, among which Kamlesh Pattni.
As of the start of January 2025, according to CiFAR’s analysis, the US Global Magnitsky regime (GLOMAG) includes 125 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 under discussion, they did not materialise in 2024. 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.
The EU misappropriation sanctions regime saw the delisting of 3 individuals in January 2024 and 2 in October 2024, all in relation to Tunisia. This means that 30 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 did add any names to its targeted anti-corruption sanction regime in 2024. 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 remain targeted due to corruption or corruption and human rights. To note here: 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 2024, 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 largely expanded its anti-corruption sanctions list in 2024, adding 14 individuals in three designation batches. In April, it targeted 3 Ugandan public officials for their alleged role in diverting state-funded roofing material designated to support vulnerable communities. In November 2024, it released a set of sanctions targeting “three notorious kleptocrats” and their allies, marking therefore the launch of a new campaign to “crack down” illicit financial flows. Among those is Isabel dos Santos, daughter of the former president, and accused of embezzling millions of USD out of Angola. Finally, on the International Anti-Corruption day and in coordination with the US sanction regime, the UK targeted 3 individuals who supposedly elaborated a large-scale companies network designed to hide corrupt profits from gold and diamond smuggling from Southern Africa. This brought the number of individuals sanctioned for corruption by the UK to 53.
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. Starting in May 2022, Switzerland commenced several confiscation proceedings with regards to these assets, some linked to Yuriy Ivanyushchenko, totalling 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 2024, no one is currently 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 2024
Regime | Removals | Additions | Total corruption designations in Dec 2024 |
US Global Magnitsky Human Rights Accountability Act | 1 | 18 | 125 |
UK Global Anti-Corruption Sanctions Regulations | 0 | 14 | 53 |
EU misappropriation sanctions Tunisia | 5 | 0 | 30 |
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) | 0 | 0 | 0 |
Total | 6 | 32 | 290* |
* The total number of listed individuals is lower (253) than the number of designations (290) because some individuals are designated multiple times, across different jurisdictions.
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 every six months. To see the individuals sanctioned for their alleged involvement in corruption or to download the complete database, please visit Sanctions Watch.