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While most US sanctions programmes allow OFAC full discretion to determine whether to implement sanctions and against whom, the Global Magnitsky Act requires the president to reply inside one hundred twenty days to a request from the heads of sure Congressional committees for a willpower as as to whether specific events engaged in human rights violations, and if that is the case, to impose sanctions. This mechanism was utilised within the sanctions imposed in response to the two October 2018, murder of journalist Jamal Khashoggi on the Saudi consulate in Istanbul. Further, Executive Order issued on 1 November 2018, authorises OFAC to sanction ‘any person determined by the Secretary of the Treasury, in session with the Secretary of State .

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