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Global Magnitsky Act Annual Report

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Published March 9th, 2026
Detected March 25th, 2026
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Summary

The U.S. Department of State has released its annual report on the implementation of the Global Magnitsky Human Rights Accountability Act for the 2025 reporting period. The report details the use of sanctions as a foreign policy tool and lists specific designations made against foreign individuals and entities for human rights abuses and corruption.

What changed

The U.S. Department of State has issued its annual report detailing the implementation of the Global Magnitsky Human Rights Accountability Act for the 2025 reporting period. This notice includes the full text of the report submitted by the Secretary of State, pursuant to Executive Order 13818. The report highlights the program's role in promoting accountability for human rights abuses and corruption globally, noting that in 2025, a net total of three foreign persons were designated, bringing the total number of designated foreign persons to 744. The report specifically lists seven foreign persons (individuals and entities) sanctioned in 2025, including designations in Brazil and Burma, for serious human rights abuses or corruption, though it also notes that some individuals and entities were subsequently removed from the SDN list.

Compliance officers should review the report to understand the scope and application of the Global Magnitsky sanctions program. While this is a notice of a report and not a new rule, the designations and removals listed provide insight into current U.S. foreign policy priorities and enforcement actions. Entities involved in international trade or financial transactions with individuals or entities mentioned in the report, or operating in the listed countries, should assess their exposure to sanctions risk and ensure compliance with OFAC regulations. No immediate compliance actions are mandated by this notice, but awareness of these designations is crucial for risk management.

What to do next

  1. Review the Global Magnitsky Act Annual Report for 2025.
  2. Assess potential sanctions risk for entities and individuals listed in the report.
  3. Ensure compliance with OFAC sanctions regulations.

Source document (simplified)

Content

ACTION:

Notice of Report.

SUMMARY:

This notice contains the text of the report required by the Global Magnitsky Human Rights Accountability Act, as submitted
by the Secretary of State pursuant to Executive Order 13818.

FOR FURTHER INFORMATION CONTACT:

Dr. Andrew Self, Email: EB-GloMagSanctions@state.gov, Phone: (202) 412 3586.

SUPPLEMENTARY INFORMATION:

On March 9, 2026, the Under Secretary of State for Political Affairs approved the following report pursuant to the Global
Magnitsky Human Rights Accountability Act (Pub. L. 114-328, Title XII, Subtitle F) (“the Act”), which is implemented and built
upon by Executive Order 13818 of December 20, 2017, “Executive Order Blocking the Property of Persons Involved in Serious
Human Rights Abuse or Corruption” (E.O. 13818). The text of the report follows:

Pursuant to Section 1264 of the Act, and consistent with E.O. 13818, the Secretary of State, in consultation with the Secretary
of the Treasury, submits this report on the implementation of the Act in the 2025 reporting period.

The Global Magnitsky sanctions program is the United States' flagship foreign policy tool for promoting accountability for
human rights abuse and corruption, globally. In 2025, the United States designated a net total of three foreign persons under
the Global Magnitsky sanctions program, bringing the number of foreign persons currently designated under the program to 744.

Throughout 2025, the Global Magnitsky sanctions program was used to advance an America First foreign policy agenda, including
championing free speech and furthering other U.S. national security interests and foreign policy goals.

Global Magnitsky Designations by Country

In 2025, the Secretary of the Treasury, in consultation with the Secretary of State and the Attorney General, imposed economic
sanctions on the following seven foreign persons (individuals and entities) pursuant to E.O. 13818:

Brazil

Alexandre de Moraes: On July 30, 2025, Brazilian Supreme Federal Court justice Alexandre de Moraes (Moraes) was designated for being a foreign
person who is responsible for or complicit in, or has directly or indirectly engaged in, serious human rights abuse, namely
arbitrary pre-trial detention involving flagrant denials of fair trial guarantees and violation of freedom of expression. Alexandre de Moraes was removed from the SDN list on December 12, 2025.

Lex Instituto de Estudos Juridicos LTDA: On September 22, 2025, the Lex Instituto de Estudos Juridicos LTDA (Lex Institute) was designated for having materially assisted,
sponsored, or provided financial, material, or technological support for, or goods or services to or in support of Moraes.
The Lex Institute acts as a holding company for Moraes, owning his residence in addition to other residential properties.
The nominal ownership of many of these properties was transferred from Moraes and his family to the Lex Institute over a decade
ago. Lex Instituto de Estudos Juridicos LTDA was removed from the SDN list on December 12, 2025.

Viviane Barci de Moraes: On September 22, 2025, Viviane Barci de Moraes (Viviane) was designated for being, or having been, a leader or official of
the Lex Institute, an entity whose property and interests in property are blocked pursuant to E.O. 13818 as a result of activities
related to Viviane's tenure. Viviane is the Managing Partner of the Lex Institute and has been the sole manager and administrator
of the Lex Institute since its establishment in 2000. Viviane Barci de Moraes was removed from the SDN list on December 12, 2025.

Burma

She Zhijiang: On September 8, 2025, She Zhijiang (She) was designated for being a foreign person who is responsible for or complicit in,
or who has directly or indirectly engaged in, serious human rights abuse, namely the mistreatment and abuse of trafficked
workers in online scam centers. She is the creator and largest shareholder of the Yatai New City scam center compound based
in Shwe Kokko, Burma. Scam operators at Yatai New City reportedly have lured recruits from around the world under false pretenses,
only to detain and physically abuse them, while forcing them to work for crime syndicates as online scammers. Concurrent with
the designation of She, the following entities were designated:

Myanmar Yatai International Holding Group Co., LTD.: On September 8, 2025, Myanmar Yatai International Holding Group Co., LTD. (Myanmar Yatai) was designated for being a foreign
person that is responsible for or complicit in, or that has directly or indirectly engaged in, serious human rights abuse,
namely the mistreatment and abuse of trafficked workers in online scam operations. Myanmar Yatai owns, operates, and profits
from Yatai New City and the scam activity happening within.

Yatai International Holdings Group Limited: On September 8, 2025, Yatai International Holdings Group Limited (Yatai IHG) was designated for being a foreign person that
is responsible for or complicit in, or that has directly or indirectly engaged in, serious human rights abuse, namely the
mistreatment and abuse of trafficked workers in online scam centers. Yatai IHG owns Myanmar Yatai with a joint venture partner.

Hungary

Antal Rogan: On January 7, 2025, Antal Rogan (Rogan) was designated for being a foreign person who is a current or former government official,
or a person acting for or on behalf of such an official, who is responsible for or complicit in, or has directly or indirectly
engaged in, corruption, including 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. Antal Rogan was removed from the SDN list on April 15, 2025.

Visa Restrictions Imposed

Persons designated pursuant to E.O. 13818 are subject to the entry restrictions articulated in section 2,

  unless an exception applies. Section 2 provides that the entry of persons designated under section 1 of the order is suspended
  pursuant to Presidential Proclamation 8693.

In 2025, the Department took steps to impose visa restrictions, when appropriate, on foreign persons involved in certain human
rights violations and significant corruption pursuant to other authorities, including Presidential Proclamation 7750 and Section
7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act. The Department will continue
to identify individuals subject to those authorities as appropriate, including but not limited to individuals designated under
the Global Magnitsky program. In addition, the Department continues to implement all grounds of inadmissibility in the Immigration
and Nationality Act (INA), including INA section 212(a)(3)(C).

Coordinated Actions With Partners and Allies

The United States recognizes that our sanctions are most impactful when implemented in coordination with our foreign partners.
Since the issuance of E.O. 13818, the United States has encouraged likeminded partners to develop their own global human rights
and anti-corruption sanctions programs, and continues to work with countries that have developed “Magnitsky-like” authorities,
including Australia, Canada, the European Union, and the United Kingdom, to advance sanctions priorities.

Samuel K. Parker, Deputy Assistant Secretary, Bureau of Economic, Energy & Business Affairs, U.S. Department of State. [FR Doc. 2026-05753 Filed 3-24-26; 8:45 am] BILLING CODE 4710-07-P

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Named provisions

Global Magnitsky Designations by Country

Classification

Agency
DOS
Published
March 9th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Substantive
Document ID
DOS_FRDOC_0001-7105

Who this affects

Applies to
Importers and exporters
Industry sector
4231 Wholesale Trade
Activity scope
Sanctions Enforcement
Geographic scope
United States US

Taxonomy

Primary area
International Trade
Operational domain
Compliance
Compliance frameworks
OFAC Sanctions
Topics
Human Rights Sanctions Corruption

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