Following the October 2024 execution of German-Iranian dual citizen Jamshid Sharmahd, Germany responded with decisive diplomatic measures. These included closing Iranian consulates in Frankfurt, Hamburg, and Munich, summoning Iran’s chargé d’affaires, and recalling its ambassador from Tehran for consultations. Meanwhile, Tehran is now denying the execution took place at all.
In the wake of high-profile human rights abuses, immediate responses often focus on prominent diplomatic actions. While these measures signal resolve, they represent only part of what should be a broader strategy.
In Germany’s case, these measures, though significant, fell short of delivering justice to Sharmahd’s family or addressing Iran’s broader pattern of human rights abuses. Diplomatic gestures alone lack the impact of being paired with concrete measures – such as Magnitsky-style sanctions – that directly target individuals responsible for human rights violations. This is especially critical in Iran, where domestic judicial accountability is absent and the very figures charged with upholding justice are often those perpetrating abuses.
Without a comprehensive survivor-centered approach, diplomatic responses risk prioritizing the appearance of accountability over addressing the actual rights and needs of victims and their families. Genuine justice requires moving beyond symbolic gestures to implement tangible, survivor-centered actions that reflect a true commitment to accountability.
Magnitsky-style sanctions provide a principled and practical framework for accountability. At least one individual involved in Sharmahd’s case – Behrouz Hasani-Etemad, Head of Branch 7 of the Security Public and Revolutionary Prosecutor’s Office of Tehran and the prosecutor’s representative during Sharmahd’s trial – could be proposed by Germany for EU Magnitsky-style designations.
With November recognized as “Magnitsky Month,” this is a timely opportunity for governments to recalibrate their strategies and leverage Magnitsky-style sanctions to hold Iranian officials accountable for their ongoing human rights abuses.
Chasing Accountability for Human Rights Violations in Iran
During the twelve months leading up to October 2024, when Sharmahd was executed, Iran carried out over 810 executions, marking the highest annual total in a decade.
The surge included more than 25 women, who are also being sentenced to mandatory psychological care centers and forced labor for defying the country’s revamped enforced hijab laws, which took effect after long legislative delays in September. Meanwhile, courts continue to impose corporal punishment – just last month two brothers were subjected to amputation for theft. In a court document, one brother stated, “I am a thief, but not in the way the police said, they forced me to confess to that number.”
Reports of arbitrary detention, torture, suppression of peaceful protests, and severe restrictions on freedom of expression and assembly have become disturbingly routine in Iran. The government’s strict enforcement of restrictive social norms has led to a sharp increase in gender-based violence, particularly against women resisting the regime’s dress codes. Ethnic and religious minorities also continue to endure entrenched discrimination, compounding an already dire human rights crisis. United Nations experts and civil society organizations have found credible evidence that these abuses constitute widespread and systematic crimes, rising to the level of crimes against humanity.
The establishment of a U.N. Fact-Finding Mission on Iran (FFMI) to document these crimes was an important step toward justice. However, its mandate’s inability to take direct action on its findings leaves a critical gap in accountability. To close this gap, States should use all available tools, including Magnitsky-style sanctions, to target those responsible for Iran’s human rights violations, particularly individuals identified by investigative mechanisms like the FFMI.
The Case for Magnitsky-Style Sanctions
Governments such as the United States, United Kingdom, EU, Australia, and Canada, have established Global Magnitsky-style sanctions regimes to target individuals and entities involved in human rights abuses and corruption. Unlike broad-based sanctions that impact entire sectors or populations, Magnitsky-style sanctions focus on specific perpetrators, applying pressure on them without harming the civilian population. These sanctions can be imposed on State actors and individuals, and when coordinated internationally, they offer a powerful mechanism to combat human rights violations globally.
Magnitsky-style sanctions offer several key advantages:
1. Public Accountability: Magnitsky-style sanctions publicly name perpetrators, damaging their international reputation. This serves as both a punishment and a symbolic acknowledgment of victims’ suffering. Survivors and activists in Iran interviewed by Human Rights Activists in Iran (HRA), where one of us works, have described these sanctions as “a glimmer of hope,” validating their experiences and demonstrating that the international community is taking action. A mother of a student who went missing during nationwide protests in 2022 shared, “Every time such a sanction is imposed, I feel like my child’s disappearance isn’t forgotten – there is a sense of validation.”
In a separate conversation, a former prisoner told HRA, “It feels reassuring. It’s important to know that these violations aren’t going unnoticed, it also brings forward the realization of how deep-rooted the issues are and we see that when they are named there is shame.”
2. Deterring Human Rights Violations: Magnitsky-style sanctions further directly target the personal and financial interests of perpetrators – freezing assets, blocking access to financial markets, and imposing travel bans. While anecdotal, survivors of human rights abuses in Iran have reported that Magnitsky-style sanctions may have had some deterrent effect. For example, a former detainee, released after Iran’s Supreme Leader ordered an amnesty for “tens of thousands” of prisoners in February 2023, shared with HRA how sanctions changed prison conditions:
“Every time new sanctions were announced the guard’s behavior changed, especially those with lower ranks. (…) We took advantage of this situation and put forward demands such as the provision of some equipment that would not normally be agreed to, but affected by the atmosphere, the officials of [redacted] prison seemed to be afraid and agree to our demands.” This suggests that sanctions can influence lower-ranking officials, potentially deterring further violations.
The individual also suggested that Iran’s decision to pardon a significant number of political prisoners was triggered by international condemnation including strong, coordinated sanctions against Iranian officials involved in the regime’s human rights abuses, noting that: “I even think that our freedom, which took place under the name of amnesty, was also a result of the message of the international community to the Iranian Government with the means of sanctioning and naming human rights violators.”
3. Disrupting Regime-Backed Corruption and Financial Ecosystems: Additionally, Magnitsky-style sanctions can target the financial structures that sustain oppressive regimes. By designating entities such as front companies and State-owned enterprises operated by regime officials, which facilitate corruption, sanctions can strike at the economic foundations that enable abuses. This approach not only cuts off critical resources but also reinforces the message that those facilitating human rights violations will face accountability. This disruption in tandem also exposes the true nature of these businesses to the Iranian public.
4. Acknowledging Abuses in the Absence of Domestic Accountability: Magnitsky-style sanctions can serve to acknowledge abuses where domestic recognition is absent. In Iran, where human rights abuses are effectively endorsed by the State and the Supreme Leader controls the head of the judiciary, victims have virtually no recourse for justice. Similarly, despite repeated calls from the U.N. and the international community, efforts to halt Iran’s abuses have so far failed. Magnitsky-style sanctions play a critical role in documenting human rights abuses, creating essential records that can support future international legal efforts. The U.S. designations following Mahsa Zhina Amini’s death in detention were groundbreaking examples in this regard, as they were the first to recognize violations against a single female victim publicly.
Evidence of Political Will
International support for Magnitsky-style sanctions targeting perpetrators of human rights abuses in Iran is growing. In the UK, lawmakers from all major parties recently expressed strong support for Magnitsky-style sanctions to hold Iranian officials accountable for the regime’s widespread abuses, including executions, extrajudicial killings, torture, and gender persecution. The UK Sanctions Minister Stephen Doughty subsequently reaffirmed the UK’s commitment to using targeted sanctions to address these violations of international law.
In the United States, as Donald Trump prepares to assume office, he has the opportunity to move beyond the “maximum pressure” campaign of his previous term, which caused severe hardship for the Iranian people without changing the Iranian regime’s behavior.
Bipartisan support for Magnitsky-style sanctions on Iran in the United States has remained strong, with the program’s authority only expanding since its inception.
For example, the Mahsa Amini Human Rights and Security Accountability (MAHSA) Act, signed into law in April 2024, mandates sanctions on Iran’s Supreme Leader, president, and affiliated entities for human rights abuses and support for terrorism. The MAHSA Act also requires the U.S. president to report to Congress annually on the status of these sanctions, making it harder for future administrations to lift them unilaterally. Similarly, in June 2024, following the death sentence of Iranian rapper Toomaj Salehi, U.S. lawmakers introduced the TOOMAJ Act. The legislation aimed to impose targeted sanctions on Iranian officials responsible for the severe human rights abuses committed by Iran’s Islamic Revolutionary Courts, particularly against political prisoners and protesters, utilizing the Global Magnitsky Act’s provisions to target individuals.
However, despite these efforts, gaps remain. While the United States has designated nearly 300 Iranian individuals and entities for human rights abuses, and the United States, UK, EU, Canada, and Australia collectively have sanctioned over 450 Iranian individuals and entities, many of these designations are not coordinated among the sanctioning States. For instance, of those sanctioned, 230 are designated by the United States but not by Canada, 183 by the United States but not the EU, and 151 by the EU but not the United States.
Furthermore, current designations often target high-level figures, while mid-level officials like IRGC interrogator Ali Hemmatian are overlooked. Hemmatian, known for his history of physical abuse against political prisoners in IRGC detention centers, including Evin Prison, where political prisoners are often held, was designated by the United States in 2021. Magnitsky-style sanctions should target officials across all ranks, including lower-ranking security commanders and judicial officials responsible for prosecuting and executing peaceful protestors and innocent civilians. This broader approach would apply pressure throughout the regime’s network, sending a clear message that no matter their positions, perpetrators will face consequences. As demonstrated in conversations with victims, targeting mid-level perpetrators like Hemmatian can also bring shame and accountability within their communities. However, as of now, Hemmatian is only designated by the United States. Expanding sanctions to target perpetrators across all ranks would enhance their effectiveness and send a stronger message.
Meanwhile, the EU has continued releasing sanctions packages targeting Iranian officials, but designations have solely concerned regional tensions and destabilization.
Since September 2023, the EU has not announced any new sanctions packages specifically targeting Iran’s human rights violations. Meanwhile, multiple sanctions packages have been introduced “in view of Iran’s military support of Russia’s war of aggression against Ukraine.”
Addressing human rights violations must remain a standalone priority. While many of the individuals targeted for destabilization designations are also complicit in severe domestic abuses, these efforts should not be conflated. Separate and simultaneous investigations into both areas are not only possible but necessary.
Tackling Iran’s destabilizing activities abroad and holding the regime accountable for its abuses at home are both critical but fundamentally distinct objectives. The EU must ensure that accountability for the regime’s crimes against Iranians is not sidelined in favor of broader geopolitical considerations.
This discrepancy highlights a missed opportunity for the EU to convey a clearer message about Iran’s ongoing rights abuses. It underscores the need for a more consistent approach to integrating human rights considerations into EU foreign policy.
A Path Forward: What Does Effective Implementation Look Like?
For Magnitsky-style sanctions to effectively deter human rights violations and hold perpetrators accountable in Iran, States should take several specific steps:
1. Cross-jurisdictional alignment is critical to prevent designated individuals from exploiting legal loopholes. Coordinated action across jurisdictions sends a unified message that impunity for human rights violations in Iran will not be tolerated. As the U.N. has stated: “Sanctions do not operate, succeed, or fail in a vacuum. The measures are most effective […] when applied as part of a comprehensive strategy.”
2. Designations should be grounded in the experiences of survivors and based on solid evidence of the targeted individual’s involvement in human rights abuses. To maintain credibility, Magnitsky-style sanctions must be used exclusively for human rights violations, not as a fig leaf for unrelated political purposes. They should be transparent, with clear justifications for each designation, while also protecting the safety of those providing information. Engaging with civil society organizations and survivor groups is key to enhancing the legitimacy, precision, and effectiveness of sanctions. These groups possess critical insights into the broader context of abuses and the networks of perpetrators, helping craft targeted sanctions policies that prioritize accountability and deter future violations. By consistently integrating this information into their decision-making processes, States can ensure that sanctions are timely, accurate, and credible.
3. Magnitsky-style sanctions must be seen as fair and impartial, especially in Iran, where concerns about Western double standards persist. Western countries are often criticized for not holding officials from allied States accountable for similar violations, making consistency and transparency in sanctioning even more important. Magnitsky-style sanctions must be consistently grounded in human rights considerations, informed by survivor experiences, and applied impartially to strengthen their credibility. Recognizing known abuses in official statements provides vital recognition for victims and creates a record for further accountability measures beyond sanctions should circumstances permit in the future.
4. Magnitsky-style sanctions cannot be viewed in isolation. While broad country-wide sanctions are intended to target the Iranian regime, they have often exacerbated socio-economic inequality, weakened civil society, and empowered the regime to pursue repressive policies. To maximize the impact of Magnitsky sanctions, broader sanctions must be regularly reviewed to mitigate their negative effects on civilians. Without such a review, Magnitsky sanctions risk being seen as part of an unjust sanctions regime, undermining their credibility and potentially fueling resentment that could weaken support for targeted accountability efforts.
5. Greater alignment is needed between the strong condemnation issued by diplomatic missions in Geneva and New York and the actions (or inactions) of their capitals. While diplomats frequently voice consensus and issue powerful condemnations of Iran’s human rights abuses in multilateral spaces, further action at the country level is often disappointing. Capitals in Europe, the UK, the United States, and Australia have the tools to target individuals and entities responsible for these abuses, but these tools need to be used more consistently, strategically, and in a coordinated manner.
Conclusion
Magnitsky-style sanctions, like any foreign policy tool, should be part of a broader, coordinated strategy to combat impunity for human rights violations in Iran. As one political prisoner in Iran interviewed by HRA put it: “It’s a ray of hope for people like me who suffer under their reign. It may not change things overnight, but it shows us that the world hasn’t turned a blind eye…It symbolizes international recognition of the injustices we face.”
In short, Magnitsky-style sanctions are not just punitive measures – they show global solidarity with Iranian victims and are a step toward holding its oppressive regime accountable both now and in the future.
With over 1,000 individuals and 80 entities implicated in serious human rights violations in Iran, according to credible reports, there is ample opportunity to take decisive, coordinated action against those most responsible.
