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AN EMPIRICAL STUDY OF THE IMPACT OF MAGNITISKY CORRUPTION SANCTIONS

For more information, please contact

Megan Musni

Senior Legal Manager Governance And Accountability ILP

megan@internationallawyersproject.org

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Research question.

What happened to people under sanctions?

Why it matters.

The impact of sanctions is not limited to behaviour change. To understand how sanctions can be best used, we need a better grasp of how they impact those targeted – rather than the “effectiveness” of sanctions

Methodology.

Desk top review + case studies of 20 individuals designated for corruption under the US Global Magnitsky programme.

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RESEARCH PROCESS

Desk-based study

    • To fill the gaps in relation to specific individuals - e.g. journalists who have been following the individuals; also to understand the typical impact of sanctions designations
    • To understand the general private-sector approach to Global Magnitsky designees

27 research interviews

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CASE STUDIES

Name

Home Jurisdiction

Date

Felix Ramon BAUTISTA ROSARIO

Dominican Republic

21 Dec 2017

Benjamin BOL MEL

South Sudan

21 Dec 2017

Artem CHAYKA

Russia

21 Dec 2017

Dan GERTLER

Israel / DRC

21 Dec 2017

Yahya JAMMEH

The Gambia

21 Dec 2017

Gulnara KARIMOVA

Uzbekistan

21 Dec 2017

Roberto Jose RIVAS REYES

Nicaragua

21 Dec 2017

Angel RONDON RIJO

Dominican Republic

21 Dec 2017

Slobodan TESIC

Serbia

21 Dec 2017

Jose Francisco LOPEZ CENTENO

Nicaragua

5 Jul 2018

Roberto SANDOVAL CASTANEDA

Mexico

17 May 2019

Ahmed AL-JUBOURI

Iraq

18 July 2019

Nawfal Hamnadi AL-SULTAN

Iraq

18 July 2019

Ajay, Atul and Rajesh GUPTA

India / South Africa

10 Oct 2019

Salim ESSA

South Africa

10 Oct 2019

Ashraf Seed Ahmed AL-CARDINAL

South Sudan

11 Oct 2019

Kur AJING ATER

South Sudan

11 Oct 2019

Kharmis Farnan Al-Khanjar AL-ISSAWI

Iraq

6 Dec 2019

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Direct Impact

 

Asset Freezes

 

Travel Bans

 

Private-Sector Action

 

Banks Ceasing Business

 

Other Companies Ceasing Business

 

Media Scrutiny

 

Home Developments

 

Criminal Investigation / Prosecution

 

Job Loss

 

Loss of Political Influence

 

Behaviour Change

 

By the Target

 

By Broader Regime/Network

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Form of Impact

Frequency of Observation

Direct Impact

 

  • Asset Freezes

9 (4x certain; 5x possible)

  • Travel Bans

2 (1x certain; 1x likely)

Private-Sector Action

 

  • Banks Ceasing Business

1 (1x possible)

  • Other Companies Ceasing Business

1 (1x possible)

Home Developments

 

  • Criminal Investigation / Prosecution

3 (2x certain; 1x possible)

  • Job Loss

1 (1x certain)

  • Loss of Political Influence

3 (3x possible)

Behaviour Change

 

  • By the Target

1 (1x certain)

  • By the Broader Regime / Network

0

No Impact

6

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NO IMPACT

  • Artem Chayka (Russia);
  • Jose Francisco Lopez Centeno (Nicaragua);
  • Ahmed Al-Jubouri (Iraq);
  • Nawfal Hamnadi Al-Sultan (Iraq);
  • Kur Ajing Ater (South Sudan); and
  • Kharmis Farnan Al-Khanjar Al-Issawi, aka Al-Khanjar (Iraq).

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RECOMMENDATIONS

  1. Governments should not assess the effectiveness of sanctions purely in terms of measurable outcomes, such as the amount of assets frozen.

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  • Governments should seek to identify and publicise corporate networks associated with targeted individuals.

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  • In determining appropriate targets for Global Magnitsky sanctions, governments should prioritise individuals who rely on the international financial system and therefore are more likely to be affected by the designation.

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  • In imposing Global Magnitsky sanctions on those whose wrongdoing has been addressed by domestic justice systems, governments should develop a clear understanding of the added value that the designation would have in the circumstances.

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LINKS TO RESEARCH AND IN DEPTH CASE STUDIES

 

  1. Empirical Study of the Impact of Magnitsky Corruption Sanctions (US Glo Mag)

https://www.internationallawyersproject.org/post/a-journey-of-20-an-empirical-study-of-the-impact-of-magnitisky-corruption-sanctions

 

2. In depth Case Studies on the Earliest Corruption Designations (US Glo Mag)

https://www.internationallawyersproject.org/post/global-magnitsky-sanctions-case-studies-on-the-earliest-corruption-designations

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