On December 20, 2017, a newly signed executive order implemented the Global Magnitsky Human Rights Accountability Act, which authorized the United States to impose sanctions on any foreign person who has engaged in gross violations of human rights, or acted as an agent on behalf of a foreign person engaged in such violations. The first round of Global Magnitsky designations included a cross-section of targets who participated in alleged human rights violations and international corruption. A natural question, given the newness of these sanctions, is: what’s next?

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