Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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9 OFAC TARGETS CORRUPT ACTORS AND HUMAN RIGHTS VIOLATORS AROUND THE WORLD On March 15, OFAC designated four individuals and one entity pursuant to the Sergei Magnitsky Rule of Law Accountability Act of 2012, which authorizes OFAC to sanction persons engaged in gross human rights abuses. These are the first designations of Russian individuals under the Magnitsky Act since Russia's invasion of Ukraine, illustrating OFAC's intent to use every arrow in its quiver to punish Russia. Three targets in this action relate to the death of Russian lawyer and whistleblower Sergei Magnitsky, for whom the legislation is named, or were connected to abuses committed against Oyub Titiev. First, OFAC sanctioned Natalia Mushnikova, a district judge in Moscow, for efforts to conceal the legal liability for the detention and death of Magnitsky while in prison on charges connected to his investigation of large-scale corruption by Russian government officials. While a judge, OFAC alleges that Mushnikova denied Magnitsky's family the opportunity to properly plead their case against the individuals responsible for Magnitsky's death, obstructed justice by concealing evidence, denied an independent autopsy, and rejected an appeal for an independent medical review. OFAC also targeted alleged abusers of Oyub Titiev, a prominent human rights defender and branch leader of the human rights organization Memorial. According to OFAC, Titiev was involved in investigating allegations of summary executions by Republic of Chechnya security officials in 2017. As punishment, Russian authorities arrested Titiev for drug possession upon falsified evidence. Titiev was later sentenced to four years in prison. For their involvement, OFAC designated the Kurchaloi District of the Chechen Republic Branch of the Ministry of Internal Affairs of the Russian Federation and two of Titiev's arresting officers, Nurid Denilbekovich Salamov and Khusein Merlovich Khutaev. OFAC also sanctioned Dzhabrail Alkhazurovich Akhmatov, the prosecutor who decided to bring charges against Titiev, for prosecuting Titiev despite reason to believe that evidence against Titiev was fabricated. On March 21, OFAC designated the Republic of the Sudan Central Reserve Police for human rights abuses against pro-democracy protestors in Khartoum. The CRP is a militarized Sudanese police unit. On January 17, 2022, the CRP reportedly fired live ammunition at protestors outside of the University of Khartoum's Faculty of Medicine, killing one person.

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