it looks like shit
EO 13818 allows the U.S. government to sanction any foreign person determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Attorney General:
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To be responsible for or complicit in, or to have directly or indirectly engaged in, serious human rights abuse. . . .
How recently must a crime have been committed for the USG to consider a designation?
Generally, the USG won’t consider designating someone for a crime committed beyond five years from the date of the public announcement of the designation determination. The sanctions need to be administered relatively close in time to the sanctioned activity in order to have the desired effect, rather than to be seen
merely as punishment for a past act. Furthermore, there is a preference for sanctions against targets engaged in ongoing or systemic violations, rather than in isolated behavior.
Does the Act sunset?
Yes, the Act sunsets 6 years after enactment, which would be December 23, 2022. No new sanctions can be imposed after this date if the Act is not reauthorized, but existing sanctions
would remain in effect unless terminated.
https://www.humanrightsfirst.org/sites/default/files/hrf-global-magnitsky-faq.pdf