by Human Rights First, New York, March 9, 2026
This briefing provides an overview of recent developments
in the U.S. government’s use of its targeted human rights
and anticorruption sanctions programs from July 1, 2025
to December 31, 2025.
Notable Developments and Patterns of Use
Infrequent Use of Targeted Human Rights and Corruption Sanctions: In the past
six months, the Trump administration has continued to use Global Magnitsky sanctions
and related sanctions programs significantly less than the Biden and first Trump
administrations. Only six targets have been sanctioned under the Global Magnitsky
program since this administration took office, and three of those – whose sanctioning
was an abuse of this program, as discussed further below – have since been delisted.
Similarly, only 23 foreign government officials and their family members have been
publicly sanctioned under the Section 7031(c) visa restriction program in that period.
The past year marks the lowest annual use of these two programs on record.
The deprioritization of these important accountability tools aligns with the Trump
administration’s narrowing or outright dismantling of the U.S. government’s human
rights and anticorruption work more broadly.
Inappropriate Uses of Global Magnitsky Sanctions: Several recent actions taken
by the Trump administration under the Global Magnitsky program during this period
have raised concerns that the program is being inappropriately used in pursuit of
impunity for friends, rather than for accountability. For example, in July, Brazilian
Federal Supreme Court Justice Alexandre de Moraes was sanctioned seemingly in
retaliation for overseeing the criminal case against former Brazilian President and
Trump ally Jair Bolsonaro and legal actions taken against Elon Musk’s companies
for failure to comply with Brazilian law and court orders. The sanctions followed the
State Department’s visa ban against Justice de Moraes under Section 212(a)(3)(C)
of the Immigration and Nationality Act (INA), the public announcement of which
violated U.S. law. Human Rights First criticized these sanctions as advancing “the
administration’s pursuit of impunity for close political allies.” The administration later
sanctioned de Moraes’ wife and a holding company, before removing the sanctions
on all three several months later, after relations between the Trump administration
and Brazil had warmed.
The Trump administration has also removed Global Magnitsky sanctions at an
unusually high rate, doing so without providing substantive explanations related
to the Global Magnitsky program’s accountability goals. Such delistings included
the removal of senior Hungarian minister Antal Rogan in April and former Paraguayan
President Horacio Manuel Cartes Jara and related companies in October. Both
Rogan and Cartes have been key figures in conservative political parties in their
respective countries, contributing to perceptions that the delistings had purely
political motivations.
Disregarding Legal Requirements for Visa Restrictions and Sanctions: The Trump
administration has repeatedly failed to adhere to statutorily mandated restrictions
on the use of visa bans and sanctions delisting requirements.
• Violations of Visa Confidentiality: Federal law prohibits the disclosure of the
specific individuals barred from entry into the United States under Section
212(a)(3)(C) visa ban policies, yet the State Department has violated visa
confidentiality requirements and identified persons determined to be ineligible
for a U.S. visa on at least four occasions during the reporting period. In three
of these instances, the Department’s official press release included the names of
those affected by the announced actions. These include actions against Justice
de Moraes, Brazilian Ministry of Health officials, and Honduran national Marlon
Ochoa. In another instance, the identities of the targeted individuals, including
former European Commissioner Thierry Breton, were disclosed by a Department
official via social media. When asked about some of these apparent violations,
State Department officials have not responded.
• Failure to Follow Global Magnitsky Delisting Requirements: The Trump
administration has also failed to provide the statutorily required notice to
Congress before terminating Global Magnitsky sanctions. When former
Paraguayan President Cartes was delisted in October, Senators Shaheen,
Kaine, and Warren published a letter criticizing the lack of advance notice
provided to Congress. This follows the administration’s similar failure to give
the required notice before the delisting of Hungarian minister Rogan in April
(and Brazilian justice de Moraes in December, though these sanctions were
inappropriate to begin with).
Targeting the Judiciary and Those Supporting Accountability: The Trump
administration has also continued its use of targeted sanctions to attack and
threaten judges and others involved in pursuing accountability. Under the International
Criminal Court sanctions program/E.O. 14203 created in February 2025, the admin
istration sanctioned four more ICC judges and two deputy prosecutors in August
and December for their roles in ICC investigations of the situations in Palestine and
Afghanistan. These actions brought the total number of ICC judges and court officials
sanctioned by the administration to eleven by the end of this reporting period.
In recent months, the administration also escalated its attacks against those
engaging with the court’s investigation of Israeli conduct in Palestine, including
unprecedented sanctions against Francesca Albanese, the UN Special Rapporteur
on the situation of human rights in the Palestinian Territories occupied since 1967
in July, and sanctions against three Palestinian human rights NGOs.
Beyond the ICC sanctions program, the administration used sanctions and intimidation
against judges in inappropriate ways. These include the sanctions and visa ban against
Brazilian justice de Moraes, his wife, and a holding company, discussed above. State
Department officials have also reportedly considered imposing sanctions against
French judges and prosecutors in response to the conviction of far-right French
politician Marine Le Pen for embezzlement. In a meeting with a French magistrate
who leads the country’s human rights commission in May, two State Department
officials reportedly claimed Le Pen was the victim of a “political conviction” and asked
if the magistrate could intervene over the resulting election ban against Le Pen.
Focus on Forced Labor in Southeast Asian Cyber Scam Centers: During the
reporting period, the Trump administration continued using sanctions to target
forced labor and other abuses occurring inside cyber scam centers located in
Myanmar and Cambodia. In September, the U.S. government imposed Global
Magnitsky sanctions on She Zhijiang and designated several other persons under
a different program in connection with a scam center known as the Yatai New
City Compound. In October, Chen Zhi and the Prince Group were designated as a
transnational criminal organization and were sanctioned for the operation of violent
and repressive cyber scam compounds in Cambodia. The U.S. government’s most
recent action against cyber scam centers came in November, targeting the
Democratic Karen Benevolent Army and its associated network.