On November 15, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated seventeen individuals as Specially Designated Nationals (“SDNs”) under Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”), in connection with the killing of journalist Jamal Khashoggi.  These individuals include Saud al-Qahtani, a former top aide to the crown prince, and Mohammed al-Otaibi, the consul general of the Saudi consulate in Istanbul where Mr. Khashoggi was killed on October 2, 2018.  The full list of the designated individuals can be found here.

The Global Magnitsky Act authorizes the President, among other things, to impose sanctions on any individual or entity who is responsible for extrajudicial killings, torture, or other gross violations of internationally recognized human rights committed against individuals in any non-US country seeking to expose illegal activity carried out by government officials, or to obtain, exercise, or promote human rights and freedoms.  Our prior blog post on the Global Magnitsky Act can be found here.

Treasury Secretary Mnuchin announced in a statement that “[t]he United States continues to diligently work to ascertain all of the facts and will hold accountable each of those we find responsible in order to achieve justice for Khashoggi’s fiancée, children, and the family he leaves behind.”

As a result of the OFAC designations, all of the property and interests in property subject to US jurisdiction of the designated individuals are blocked, and “US Persons” are generally prohibited from engaging in transactions with these individuals and any entities 50% or more owned by these individuals.  “US Persons” include (i) entities organized under US laws and their non-US branches, (ii) individuals or entities in the United States, or (iii) US citizens or permanent resident aliens (“Green Card” holders) wherever located or employed.  Non-US persons may be liable if they cause any US Persons to engage in any prohibited SDN-related transactions.


Mr. Coward focuses on outbound trade compliance matters, including the extraterritorial application of US law, particularly US export control laws, anti-boycott regulations and trade sanctions/embargoes maintained by the US government against various countries. In addition, his practice covers issues of corporate conduct such as the application of the Foreign Corrupt Practices Act and foreign bribery laws. He provides international transactional advice; assistance in the design and implementation of corporate compliance programs, compliance audits, and internal investigations; and representation in enforcement proceedings.


Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.


Callie C. Lefevre is an associate in the Washington, DC office where she is a member of the International Practice Group. Her practice is focused on all aspects of International Trade law, particularly compliance with US export controls, trade and economic sanctions, and US foreign investment restrictions. *Admitted in New York only. Practice limited to matters and proceedings before US courts and federal agencies.