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Presidential Memorandum

Delegation of Authority Under the Global Magnitsky Human Rights Accountability Act

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

Impact dates

  1. 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

Timeline

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
Presidential Memorandum: Delegation of Authority Under the Global Magnitsky Human Rights Accountability Act · Executive Orders