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Who will be affected by the American sanctions?

by Robert Duigan | Jul 26, 2025

Key Article

While several high-ranking officials will now be at risk, the question of the donor class is also a potential issue

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The latest bill sanctioning South Africa’s political leadership, the U.S.-South Africa Bilateral Relations Review Act of 2025, has just passed the House Foreign Affairs Committee, and will be sent to the floor to be voted on shortly.

It is a broad condemnation of the ANC government’s deviation from its stated nonpartisan position in international relations, attacking them for being close to Hamas, Iran, Russia and China. The text of the bill describes several detailed transgressions of American interest, from Chinese political training schools, to Russian arms smuggling, party donations from sanctioned individuals, and much more besides.

The President will, within 120 days of the bill’s passage, sanction any leader deemed to have transgressed norms described by the Global Magnitsky Human Rights Accountability Act.Provision for exemptions is made in the same paragraph. The Magnitsky Act itself describes these acts as follows, covering both human rights and corruption:

“gross violations of internationally recognized human rights committed against individuals in any foreign country who seek […] to expose illegal activity carried out by government officials; or to obtain, exercise, defend, or promote internationally recognized human rights and freedoms […]; acted as an agent of or on behalf of a foreign person in a matter relating to an activity described in paragraph; is a government official, or a senior associate of such an official, that is responsible for, or complicit in, […] acts of significant corruption […] has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, an activity described”.

The sanctions as including prohibiting entry to the united States, the blocking “of all transactions in all property and interests in property of a foreign person if such property and interests in property are in the United States, come within the United States, or are or come within the possession or control of a United States person”, except the import of goods.

Past use of the bill

The Magnitsky Act has usually sanctioned government officials directly responsible for abuses. It was brought about in 2012, nominally response to the murder of tax lawyer Sergei Magnitsky in a Moscow prison after investigating mass fraud by Russian tax officials, and has been used to cut Russia’s diplomatic ties as the Obama administration sought to ratchet up the pressure and isolate the country, and build toward potential regime change. Several Russian officials were thus targeted.

The Wikipedia page for the Act describes a long list of prominent foreign officials in countries unfriendly to the United States who have been targeted by the Act, usually for some tangible action, like the assassination of Jamal Kashaggi, or China’s failure to adhere to the terms of the Sino–British Joint Declaration and Hong Kong’s Basic Law. In Nicaragua, officials were targeted for suppressing dissent, while in the Dominican Republic, a senator faced sanctions for bribery tied to public works contracts.

Effectively, illegal or unethical behaviour by powerful individuals within a country creates an attack vector by which the United States may apply pressure on states who deviate from its foreign policy aims. Only sterling behaviour can possibly generate room to set an autonomous foreign policy without being affected, and no state is ever entirely free of blemish, even at the highest level.

Specific Individuals

While the exact list depends on the U.S. President’s assessment, speculation based on public discourse (e.g., posts on X) suggests potential targets like President Cyril Ramaphosa, Deputy President Paul Mashatile, ANC Secretary-General Fikile Mbalula, or others tied to foreign policy or corruption allegations (e.g., Gwede Mantashe, Jacob Zuma, Ronald Lamola). However, these remain unconfirmed until the official list is submitted. The focus will likely be on high-profile figures driving the policies criticized in the bill.

Because the Magnitsky Act allows sanctions against individuals who have “materially assisted, sponsored, or provided financial, material, or technological support” for activities involving human rights abuses or corruption, the question is raised whether political donors to the ANC could be affected.

The answer would depend on the nature and purpose of their contributions, of course, but if they haven’t demonstrated to American authorities that they are properly aligned, they may find themselves at risk. For example, the bill references Russian oligarch Viktor Vekselberg, a sanctioned individual, who reportedly donated to the ANC in 2022. Past Magnitsky sanctions have focused on direct actors (e.g., officials), but the “material support” clause broadens the scope to include enablers. Donations to the ANC without a clear link to sanctionable activities are unlikely to trigger sanctions.

However, several individuals could be seen to be extracting a quid pro quo, and long-term major donors like Johann Rupert may be at risk if the United States deems the pressure the ANC and DA placed on the Competition Commission to ram through his Maziv deal with Vodacom to stem from a corrupt relationship.

There is no precedent in past cases for political donors being sanctioned solely for supporting a party, but proof of enabling specific violations could trigger their inclusion.

The bill’s emphasis on ties to Russia, Iran, and China suggests that donors from these countries—or those acting as proxies—could face scrutiny. If a donor’s contribution is part of a broader effort to advance the interests of a sanctioned state (e.g., Russia) in ways that violate Magnitsky norms, they might be sanctioned. However, this requires concrete evidence, which will be assessed by the U.S. government.

Within the ANC, examples like President Ramaphosa and Naledi Pandor are a given, though the final list remains pending. We can only know for sure who is going down when that is published.

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