Delegation of Authority Under the Global Magnitsky Human Rights Accountability Act

Defense & Security Democracy & Governance

In simple terms

This memorandum delegates authority under the Global Magnitsky Human Rights Accountability Act: the Treasury Secretary receives authority to administer financial sanctions, and the State Secretary receives authority to administer visa sanctions, with Treasury required to coordinate with State. The delegations automatically apply to any future law substantially similar to section 1263 of the Act.

Federal Register Open PDF 82 FR 45411

Record & deadlines

Sep 8, 2017Signed
Signed by the President
Sep 28, 2017FR published
Published in the Federal Register · 82 FR 45411
Federal Register PDF
Date TBD
Federal Register publication by Secretary of State

Key directives

Delegate financial sanctions authority under section 1263 to Secretary of the Treasury
Delegate visa sanctions authority under section 1263 to Secretary of State
Treasury must coordinate with State in exercising delegated authority
Apply delegations to future public laws substantially same as section 1263
State Secretary must publish memorandum in Federal Register

Who is ordered

What to expect

Immediate

Delegation of sanctions authority to Treasury and State takes effect
Treasury-State coordination requirement begins

Near term (90d)

—

Long term

Ongoing sanctions administration under Global Magnitsky framework
Automatic application to future substantially similar legislation

Risks & tensions

Automatic extension to future laws creates open-ended delegation with uncertain scope
Coordination requirement between Treasury and State may create bureaucratic friction in sanctions decisions
No explicit dispute resolution mechanism if agencies disagree on sanctions applications