The US has terminated its Zimbabwe sanctions program, but has designated 11 individuals, including Zimbabwe’s President and three entities for their involvement in corruption or serious human rights abuse.

In short, the country program has gone, but the US continues to have serious human rights concerns about the country’s governments and has moved to a more targeted approach.

The unilateral sanctions imposed by the US, EU and UK have been criticised by the African Union and the ‘UN Special Rapporteur on unilateral coercive measures’ as causing unnecessary suffering on the people of Zimbabwe. This seems to have been at least a factor in the US President’s latest Executive Order.

Points to note:

1. The US may have terminated the Zimbabwe program, but some individuals and entities in Zimbabwe are still SDNs under the US thematic Magnitsky sanctions.
2. The EU and the UK – for now at least – continue to have sanctions in place and those commercial operators subject to UK or EU jurisdiction will still need to be mindful of how they approach business with a Zimbabwean connection (as with any country targeted by sanctions).