“There is a considerable amount of convergence between Britain’s 49 designations on July 6 and the U.S. sanctions list. Indeed, the vast majority of individuals that Britain sanctioned pursuant to its 2018 Magnitsky Act already appear on the U.S. ‘specially-designated nationals’ list—effectively a blacklist of persons and entities with whom any business is prohibited—and for the same reasons. For example, all 25 Russian individuals sanctioned by Britain for their involvement in the killing of Magnitsky, who died in police custody after reporting fraud by local government officials, were also sanctioned by the U.S. under the 2012 Magnitsky Act, which was specifically passed to authorize reprisals against those parties involved in his death. Likewise, the two Burmese generals sanctioned by the U.K. for violence against the Rohingya were also sanctioned by the U.S. under the 2016 Global Magnitsky Human Rights Accountability Act, which authorizes sanctions against human rights abuses anywhere in the world. As Elizabeth Rosenberg, a former special adviser to the Treasury Department’s Office of Foreign Assets Control (OFAC), told me, ‘The U.K. named many of the most infamous U.S. designees in order to affirm the U.S. approach and build solidarity around the practice of using sanctions to expose and target human rights abuse…'”