Is Executive Order 13818 Still Active or Revoked?

Executive Order 13818 is still active. Signed on December 20, 2017, the order was most recently renewed on December 10, 2025, keeping its authority in place through at least December 20, 2026.¹ It freezes the U.S. assets of foreign individuals and entities involved in serious human rights abuse or corruption, bars them from entering the country, and makes it illegal for any U.S. person to do business with them. The order is the legal backbone of the Global Magnitsky sanctions program.

Why It Has To Be Renewed Every Year

The order operates by declaring a national emergency under the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act.² Under federal law, a national emergency automatically expires on its anniversary date unless the President publishes a continuation notice in the Federal Register at least 90 days beforehand.³ Every administration since 2017 has issued that renewal. The most recent continuation was published on December 12, 2025.¹

What The Order Does

Asset Blocking

When a foreign person or entity is designated under EO 13818, all their property and interests in property that are in the United States, that later enter the United States, or that fall within the possession or control of any U.S. person are frozen.² Frozen assets cannot be moved, spent, exported, or withdrawn. Bank accounts, real estate, and investment holdings are all covered. U.S. persons, meaning citizens, permanent residents, and entities organized under U.S. law, are broadly prohibited from conducting any transaction with the designated party.⁴

Entry Ban

Section 2 of the order suspends entry into the United States for designated foreign persons, as either immigrants or nonimmigrants, on the basis that their presence would be detrimental to the interests of the United States.² Existing visas can be revoked as part of the designation.

The 50 Percent Ownership Reach

OFAC treats any entity owned 50 percent or more by one or more sanctioned persons as if it were on the list itself, even if it has never been named. Ownership stakes among multiple sanctioned individuals are aggregated toward that threshold. OFAC can also designate entities where sanctioned persons hold less than 50 percent but exercise control over operations.

Who Can Be Designated

Designations fall into two categories. The human rights category covers foreign persons responsible for or complicit in serious abuses, including extrajudicial killings, torture, and other gross violations of internationally recognized human rights.⁴ The corruption category targets current or former government officials, or people acting on their behalf, engaged in bribery, misappropriation of state assets, expropriation of private assets for personal gain, and corruption tied to government contracts or natural resource extraction.² Facilitating the transfer of corruption proceeds also qualifies.

The reach extends beyond principal wrongdoers. Anyone who materially assisted, sponsored, or financially supported sanctioned activities can be designated, as can leaders of organizations that engaged in qualifying conduct during their tenure.⁴ Treasury makes the final call in consultation with the State Department and the Attorney General.⁵ In 2024 alone, 70 foreign persons were designated under the Global Magnitsky program.

What A Violation Costs

Because EO 13818 draws its authority from IEEPA, the penalties in federal law apply to anyone who conducts a prohibited transaction, moves blocked assets, or helps a designated person evade sanctions.

Willful violations can bring up to 20 years in prison and a fine of up to $1,000,000.⁶
Civil penalties, which do not require willful intent, reach up to $377,700 per violation (adjusted for inflation) or twice the value of the underlying transaction, whichever is greater.⁶

The “twice the transaction value” multiplier is where large deals get expensive fast. A single prohibited $5 million wire could generate a $10 million civil penalty, before any criminal case. Aiding, abetting, or conspiring to violate the sanctions carries the same penalties as committing the violation directly.

If You Hold Blocked Property

Freezing the assets is not enough. Federal regulations impose two reporting obligations on any U.S. person who ends up holding or rejecting property tied to a designated party.

An initial report to OFAC is due within 10 business days of blocking property or rejecting a transaction.⁷
An annual report on all blocked property is due to OFAC by September 30 each year.⁸

These requirements are not limited to banks. A landlord whose tenant turns out to be designated, or a company that discovers a blocked person holds equity in a joint venture, has the same clock running from the moment the blocked property comes to light.

Getting Off The List

Someone placed on the SDN list under EO 13818 can petition OFAC for removal. A lawyer is not required, though most petitioners retain one. The petition goes by email to OFAC.Reconsideration@treasury.gov; OFAC does not accept removal requests by phone.⁹ It must include the listed person’s name, mailing address, email address, proof of identity such as a government-issued ID, the date of the listing, the SDN listing as it appears on the list, and a detailed explanation of why removal is warranted. The argument can be that the original basis was insufficient or that the circumstances no longer apply.

OFAC typically acknowledges receipt within seven business days and aims to send its first follow-up questionnaire within 90 days.⁹ Beyond that, timelines vary. Interagency consultations, factual complexity, and the petitioner’s response speed all affect how long the process takes. Submitting false or misleading information can result in denial and referral to law enforcement.

Which Agencies Run It

Three federal agencies share the program. Treasury’s Office of Foreign Assets Control (OFAC) handles day-to-day administration, adds names to the SDN list, issues compliance regulations, and processes license applications.⁵ The State Department handles diplomatic engagement and recommends targets. The Department of Justice investigates and prosecutes criminal violations, which is where the 20-year sentences and million-dollar fines come from.⁶

The split matters in practice. Treasury can impose civil penalties administratively without a court. Criminal prosecution through DOJ requires proof of willfulness, a higher bar, but carries far harsher consequences. Many enforcement actions run on both tracks at once.

1
Federal Register. Continuation of the National Emergency With Respect to Serious Human Rights Abuse and Corruption
2
The American Presidency Project. Executive Order 13818 – Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption
3
U.S. Government Publishing Office. House Document 118-90 – Continuation of the National Emergency With Respect to Serious Human Rights Abuse and Corruption
4
eCFR. 31 CFR 583.201 – Prohibited Transactions
5
U.S. Department of the Treasury. United States Sanctions Human Rights Abusers and Corrupt Actors Across the Globe
6
Office of the Law Revision Counsel. 50 USC 1705 – Penalties
7
eCFR. 31 CFR 501.603
8
U.S. Department of the Treasury. FAQ 50
9
U.S. Department of the Treasury. Filing a Petition for Removal from an OFAC List