Proposed US sanctions against South African officials ‘serious risk’ for organisations and individuals

The US-South Africa Bilateral Relations Review Act of 2025 (H.R.2633) was introduced by Representative Ronny Jackson in April 2025, following public overtures by the Trump administration that it would sanction the South African government for an alleged anti-American agenda and debateable claims of persecution of white citizens since the beginning of the year.

The bill has passed the House Foreign Affairs Committee, with 34 votes in favour and 16 against, and is now awaiting debate and approval by the full House of Representatives. If approved, it will then move to the senate and finally President Donald Trump for enactment.

Edward James, a sanctions law expert at Pinsent Masons, said: "Whilst ANC and government officials may have hoped that President Cyril Ramaphosa's recent charm offensive would have stopped the previous draft bill, the bill is one step closer to becoming law.”

“For individuals, the consequences of being sanctioned are serious,” he said.

“They may face bank accounts being closed, challenges in international travel and businesses being unwilling, or unable, to engage with them.”

The bill mandates a comprehensive review of diplomatic, trade, and military cooperation between the US and South Africa and cites concerns of South Africa's perceived anti-US alignment on multiple fronts, while also calling for sanctions against senior government and ANC officials.

James said: “In practice this means we are one step closer to seeing the US sanction senior ANC and government officials in South Africa and it marks a startling turn of events given the historical context.

“International sanctions played a key role in bringing an end to the oppressive apartheid regime and the ANC’s rise to power. Now key figures in the same political party face the prospect of being the target,” he said.

“The move should not come as a surprise given South Africa’s recent foreign policy positions, which – whether based on fact or perception – are increasingly seen as unfriendly to US interests.”

If passed, President Trump will be required to submit a list of senior government and ANC officials who meet the criteria to be sanctioned – namely, corruption and human rights abuses covered by the Magnitsky Human Rights Accountability Act – within 120 days of the Act becoming law.

James said: “Whilst there is no guarantee the bill will become law, or that any officials will get sanctioned, we are now at a point where the possibility has become more of a reality.”

“The prudent thing for South African companies to do is to make sure they know if they are or are not at risk of being subject to US sanctions. If so, they should get their house in order now and make sure their compliance screening processes are up to scratch,” he said.

“This will be a key compliance measure to timeously identify counterparties that they can no longer do business with, if the bill becomes law and Trump decides to sanction key officials. In the meantime, we can only hope that common sense and diplomacy prevail, and that the bill does not actually become law.”