On November 15, OFAC imposed economic sanctions against 17 Saudi officials for their participation in the killing of Jamal Khashoggi. Khashoggi, a journalist and “royal insider-turned-critic of Saudi policy”, was murdered at the Saudi Arabian consulate in Istanbul, Turkey on October 2, 2018. Among the men designated in yesterday’s action are Saud Al-Qahtani—a top aide to Saudi Crown Prince Mohammed bin Salman—and Saudi Consul General Mohammed Alotaibi. These individuals were designated pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act targeting perpetrators of serious human rights abuse and corruption.

Yesterday’s designations were announced hours after Saudi Arabia’s public prosecutor said the death penalty was being sought for five out of eleven suspects charged in Khashoggi’s murder in Saudi Arabia. The economic sanctions do not target the Riyadh government or the Crown Prince, who the Saudi foreign minister said had “absolutely nothing to do” with the murder. Nonetheless, US officials have continued to press the Saudi government for a full investigation.

The Treasury has also left open the door for additional actions against the designated individuals and others. According to Treasury Secretary Steven Mnuchin, “The 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.” US Secretary of State Mike Pompeo also called the announcement “an important step” in the response to Khashoggi’s killing and said his department would continue to seek facts, consult with Congress, and work with other countries to hold accountable anyone involved.

These designations reflect the latest round of the Trump Administration’s fairly aggressive use of this global human rights sanctions tool. Since President Trump issued Executive Order 13818 in December of 2017, the US government has designated 101 individuals and entities, from over 20 countries, for sanctions under this authority.