Clifford Chance
New OFAC Executive Order Targeting Human Rights Abuses, Corruption, and the Transfer of the Proceeds of Corruption has Broad Implications
28 December 2017
On December 20, 2017, the President significantly extended the potential extraterritoriality of US foreign bribery laws by issuing an Executive Order "Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption". This EO implements the Global Magnitsky Human Rights Accountability Act, targeting serious human rights abuses, corruption, and the transfer of the proceeds of corruption. Without defining corruption, the EO states that it includes "the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery."
