On March 4, 2024, President Biden terminated the US Zimbabwe sanctions program, unblocking all individuals, entities and property that had been blocked under that authority. Concurrently, the US imposed Global Magnitsky sanctions on 11 individuals and three entities that had been blocked under the now-repealed Zimbabwe program. In doing so, OFAC also made clear that it would continue with investigations or enforcement actions for apparent violations of the Zimbabwe sanctions while they were in effect.

In a move that the US said was intended to “refocus” the US sanctions related to Zimbabwe to “make clear” that they are “not intended to target the people of Zimbabwe” but rather, are intended to impact certain “clear and specific targets,” President Biden terminated the national emergency regarding Zimbabwe that was first declared by President George W. Bush in Executive Order 13228 from 2003. President Biden revoked that executive order as well as two that built upon it (i.e., Executive Order 13391 of 2005 and Executive Order 13469 of 2008).

As a result of the revocation, all of the individuals, entities, and property that had been blocked under the Zimbabwe sanctions program became unblocked, except those that were simultaneously re-designated under Global Magnitsky. The Zimbabwe Sanctions Regulations, further, have been removed from the Code of Federal Regulations. Moreover, by revoking the underlying legal authorities for the Zimbabwe sanctions, the US has removed several Zimbabwe-specific bases for the imposition of sanctions, such as for being a Zimbabwe government official, or for being owned or controlled by, or providing material and other support to, the government of Zimbabwe.

While the commercial impact of this revocation remains to be seen, it would appear that the US has removed at least some provisions that had posed a heightened compliance risk for doing business in Zimbabwe, especially business that involved the government of Zimbabwe. Even without a Zimbabwe-specific sanctions program, however, the US made it clear that it can impose sanctions on individuals and entities in Zimbabwe under other sanctions authorities, including Global Magnitsky. Additionally, consistent with past practice, OFAC retains the authority to penalize any violations of the Zimbabwe Sanctions Regulations that occurred while they were in effect.