Global Magnitsky Sanctions Regulations — comprehensive reissuance (31 CFR Part 583)

Mechanism

The Global Magnitsky Sanctions Regulations (31 CFR Part 583) implement two legal authorities: the Global Magnitsky Human Rights Accountability Act (Pub. L. 114-328, §§ 1261–1265) and Executive Order 13818 of 20 December 2017, which expanded the program to target serious human-rights abusers and corrupt actors anywhere in the world (not only in Russia, which was the original Magnitsky Act's scope).

OFAC reissued the regulations in their entirety — rather than issuing targeted amendments — because the volume of new sections and updated definitions warranted a clean restatement. The prior part 583 had been a sparse skeleton; the 2024 version is a fully-developed regulatory framework comparable to OFAC's more mature country-program regulations.

Key substantive changes:

1. New general licenses — The reissuance codifies standing authorisations that had previously existed only as FAQ guidance or unpublished OFAC interpretations: - Blocked-account management: transfers between blocked accounts at the same institution, routine service charges, investment/reinvestment of blocked funds - Legal services: counsel, representation, initiation of legal proceedings relating to sanctions compliance — previously relied on informal guidance - Personal humanitarian: agricultural commodities, medicines, and medical devices for the personal use of blocked individuals - Emergency medical and certain emergency legal services

2. New definitions — Agricultural commodities, medicines, and medical devices are now formally defined in 31 CFR 583, aligning the Global Magnitsky program with the definitional framework used in other OFAC programs (Iran, Cuba) and reducing ambiguity for humanitarian transactions.

3. Expanded authority citation — The Uyghur Human Rights Policy Act of 2020 (22 U.S.C. 6901 note; Pub. L. 116-145) is added to the authority citation of 31 CFR Part 583. This links the Global Magnitsky program explicitly to Uyghur-related human-rights accountability, providing additional statutory grounding for designations related to Xinjiang forced-labour abuses.

4. Interpretive guidance — New provisions clarify OFAC's "any interest whatsoever" blocking standard, constructive-knowledge tests, and recordkeeping obligations for persons holding blocked property.

Downstream implications

• Financial institutions, payments processors, and legal advisers must update their

Global Magnitsky compliance procedures to incorporate the new general-licence framework; the old stance of case-by-case licence requests for blocked-account management and routine legal services is now replaced by self-executing authorisations.

• The Uyghur Human Rights Policy Act citation opens a clearer legal pathway for future

Global Magnitsky SDN designations targeting Xinjiang supply-chain actors, supplementing the Uyghur Forced Labor Prevention Act import-ban track.

• Civil penalties for violations remain up to $368,136 per count; criminal penalties up

to 20 years imprisonment. The expanded regulatory text provides less room for "good-faith ambiguity" defences in enforcement proceedings.

Open questions

• Whether OFAC will use the Uyghur statutory hook to expand Xinjiang-related SDN

listings under the Global Magnitsky program, or continue to rely primarily on the UFLPA and sector-specific orders.

• Whether the new general licences are adopted as templates in subsequent reissuances

of other OFAC country-program regulations, or remain Global-Magnitsky-specific.