Arkady Rotenberg, Vladimir Putin’s childhood judo partner, is living large. Despite using his relationship with Putin to facilitate state capture, gaining lucrative contracts for everything from constructing the bridge between Russia and Crimea to hosting spurious “anticorruption trainings” for state employees, and being subject to American sanctions since 2014, Rotenberg maintains extensive links with the global economy. He has used Deutschebank to move millions of dollars out of Russia, channeled investments through a technology firm co-owned with a member of the British royal family, and hired a well-connected Monegasque lawyer to manage his taxes and PR. Rotenberg is not alone: Corrupt officials around the world, and their cronies, use Western professional service providers to facilitate their use of corrupt funds.

The United States has a powerful and under-utilized tool to control connections between corrupt officials and the professionals service providers who enable them: the Global Magnitsky Act (sometimes shortened to “GloMag”), which authorizes the U.S. government to impose targeted sanctions on individuals engaged in serious human rights abuses and/or high-level corruption. To date, the U.S. has imposed GloMag sanctions on 299 persons deemed to have been involved in official corruption. Yet despite some high profile successes (see here, here, and here), critics have pointed out that GloMag remains too limited in scope to seriously impact many of its targets. Sanctions against corrupt officials remain mostly unilateral tools, with governments often failing to coordinate their sanctions, leaving opportunities for evasion (see here and here). And while GloMag has inspired similar efforts by 35 additional countries, many of these governments—and the European Union—use GloMag-inspired programs only to target human rights abusers, not those engaged in grand corruption (see here and here).

There have been proposals to increase the comprehensiveness of GloMag sanctions, ranging from simply listing more corrupt officials to convincing the EU to broaden its sanctions regime to cover those engaged in high-level corruption. While these are worthwhile efforts, the United States possesses an extremely powerful tool that it could use unilaterally to drastically increase the heft of GloMag sanctions, one which is already authorized by statute and executive order: secondary sanctions. Secondary sanctions are sanctions that are imposed on a set of persons or entities that transact with an individual who is subject to primary sanctions under GloMag or a comparable regime. The U.S. can and should impose secondary sanctions on the professional service providers (such as accountants, wealth managers, bankers, and real estate agents) that provide individuals covered by GloMag sanctions with the services they need to launder the proceeds of their corruption. Under such a regime, for example, if Deutchebank helps Arkady Rotenberg (already the target of sanctions) to move his money around the world, then the U.S. would also sanction Deutschebank—restricting its ability to transact using U.S. dollars, a disastrous outcome for many firms.

To be clear, the proposal is not that secondary GloMag sanctions ought to apply to any person or entity that engages in any kind of transaction with someone on the GloMag sanctions list. Rather, the proposal is to impose secondary sanctions on professional services providers who are central to enabling corrupt officials and others to launder the proceeds of illicit activity, helping them purchase real estate, establish shell companies, and structure personal investments so as to place wealth gained through corruption outside the reach of law enforcement and into the global economy (see here, here, and here). Expanding GloMag sanctions to include secondary sanctions on professional enablers associated with money laundering and the protection of ill-gotten wealth would be effective for two separate but related reasons:

First, in contrast to traditional sanctions, secondary sanctions have proven effective at pressuring non-American firms to implement effective compliance programs, for fear of losing access to the American market and the U.S. dollar. (Although many professional service providers already have compliance programs aimed at avoiding interactions with sanctioned persons, it is questionable how effective these measures actually are. For example, a survey of 12,000 financial institutions found that approximately 5% of them were, when asked, willing to assist front-men posing as sanctioned persons in setting up shell companies.) Indeed, secondary sanctions would compel firms—even foreign firms whose governments have not imposed GloMag-style sanctions—to cut ties with sanctioned officials. To illustrate, in the early 2010s, the U.S. not only imposed primary sanctions against Iran, but also imposed secondary sanctions against institutions that facilitated Iranian access to the global financial system. Iran’s interactions with its European and Asian trading partners decreased drastically as third-country firms cut contacts with Iran and governments imposed their own sanctions to mitigate the possibility that their nationals might lose access to U.S. financial markets (see here, here, and here). Secondary GloMag sanctions would work in much the same way, inducing firms and countries to self-police more aggressively for fear of losing access to the U.S. financial system, and inducing states to effectively enact the GloMag’s anticorruption provisions where they have yet to do so.

Second, targeting corruption-enabling professional services providers with secondary GloMag sanctions will disrupt the network of shady offshore enablers that facilitate corruption and money laundering—not only by those subject to GloMag sanctions, but also those who aren’t. One analysis found that ultra-wealthy and politically connected individuals rely on a relatively small group of wealth managers, accountants, lawyers, and other service providers, which makes that system “ultra-fragile,” and prone to failure if a small number of nodes disappear. Another study, focused on a set of African countries, found a similar level of concentration among the professional enablers utilized by corrupt officials. If accurate, these studies suggest that secondary sanctions imposed against even a small group of enablers could substantially reduce the ability of a large group of corrupt officials abroad to launder and utilize the proceeds of corruption.

The authority to impose secondary GloMag sanctions already exists under U.S. law. Both section 1263 of the GloMag and Executive Order 13818, which implements the act’s provisions, authorize sanctions against individuals who “materially assisted” or “provided financial . . . support for” significant corruption by any foreign person. Notably, both the GloMag and Executive Order 13818 include “the transfer . . . of the proceeds of corruption” within their definitions of significant corruption. This language does not authorize sanctions against every professional service provider who merely transacts with a sanctioned person, but it does authorize secondary sanctions against enablers who directly assist in facilitating corruption by helping conceal or deploy the proceeds of corruption. While these measures could be imposed without intent or actual knowledge on the part of the facilitator, their scope could be calibrated to require such a finding. Consequently, the U.S. Department of the Treasury could begin listing these enablers as sanctioned entities without the need for any legislative amendments to the statute.

To be sure, secondary sanctions carry risks. They could cause friction with other governments (see here and here), and the overuse of sanctions could undermine their long-term effectiveness. But these risks are manageable. The potential for targeted secondary sanctions to enhance the Global Magnitsky Act’s impact, both further punishing foreign corrupt officials and dissuading firms from assisting in the concealment and management of corrupt foreign wealth, means that the U.S. should pursue this option more aggressively.