Sanctions Map: Who Sanctioned Whom and What It Means

A comprehensive tracker of international sanctions on Georgian officials and entities — and the gaps that remain.

Since Georgia’s democratic crisis escalated in 2024, Western governments have imposed an expanding web of sanctions on Georgian officials, judges, law enforcement commanders, and media entities. The actions span multiple jurisdictions and legal regimes — from US Treasury OFAC designations that freeze global assets, to UK sanctions targeting the justice system, to Baltic national measures and OSCE investigative mechanisms.

As of March 2026, Transparency International Georgia counts more than 230 Georgian Dream-linked individuals subject to some form of Western sanctions or visa restrictions — 141 of them publicly named. The sanctions landscape is complex: some individuals face asset freezes, others face travel bans, and many are subject to anonymous visa restrictions whose targets are never publicly confirmed.

Yet significant gaps remain. The European Union has not imposed personal sanctions. Key architects of repression remain untouched. This article maps every confirmed action, explains the legal mechanisms, and identifies what’s missing.

The United States — Leading the Response

US OFAC — Global Magnitsky Designations

The US Treasury’s Office of Foreign Assets Control (OFAC) has imposed the most consequential sanctions through three rounds of Global Magnitsky designations under Executive Order 13818:

Round 1: September 16, 2024

Four individuals designated — two senior Ministry of Internal Affairs officials and two extremist leaders responsible for orchestrating violence against protesters and journalists. Treasury stated these individuals “use violence and intimidation” to achieve anti-democratic aims. (Source: US Treasury JY2580)

Round 2: December 18, 2024

Two MoIA officials designated:

• Vakhtang Gomelauri — Minister of Internal Affairs
• Mirza Kezevadze — Senior official, Department of Special Assignments

Treasury cited “brutal crackdowns on media members, opposition figures, and protesters — including during demonstrations throughout 2024.” (Source: US Treasury JY2759)

Round 3: December 27, 2024

Bidzina Ivanishvili designated — founder and informal leader of Georgian Dream. Accused of “corruptly using his influence over Georgia’s government to enrich himself and his associates, and of undermining Georgia’s democratic institutions and Euro-Atlantic integration.” (Source: BBC)

US State Department — Visa Restrictions

The State Department has imposed multiple rounds of escalating visa restrictions:

• May 22, 2024: New visa restriction policy announced for individuals “responsible for or complicit in undermining democracy in Georgia.”
• June 6, 2024: Up to 30 Georgian Dream officials and family members restricted.
• September 16, 2024: More than 60 individuals and family members restricted.
• Mid-December 2024: Approximately 20 additional individuals.

Names are not published due to visa confidentiality rules. This makes the visa restriction program the largest in scope but least transparent of all US actions against Georgia.

US State Department — Section 7031(c) Public Designations

On April 4, 2023, the State Department issued public visa ineligibility designations for several judges and officials for “significant corruption,” including Levan Murusidze and Mikheil Chinchaladze — key members of the so-called “Clan of Judges.” These were the earliest Western sanctions targeting Georgian officials and specifically named the judiciary as a corruption vector. (Source: US Embassy Tbilisi)

The United Kingdom — Targeting the Justice System

The UK has taken a distinctive approach, extending sanctions beyond the security apparatus to target the judiciary and media:

Wave 1: December 18–19, 2024

Five Georgian officials designated under the UK Global Human Rights Sanctions Regulations (Sanctions and Anti-Money Laundering Act 2018), coordinated with US OFAC moves. Targeted senior MoIA and Department of Special Assignments figures. (Source: OC Media)

Wave 2: Early April 2025

Four senior officials designated:

• Levan Murusidze — Appeals court judge
• Mikheil Chinchaladze — Chair, Tbilisi Court of Appeal
• Giorgi Gabitashvili — Prosecutor General
• One additional senior justice-sector figure

The UK became the first country to sanction Georgia’s top prosecutor. (Source: JAMnews)

Wave 3: February 24, 2026

Entity sanctions on Imedi TV and POSTV under the Russia (Sanctions) (EU Exit) Regulations 2019 — for “deliberately spreading false information about Russia’s war in Ukraine.” Effects include frozen bank accounts, inability to make international payments, loss of Western broadcast accreditation. This marked the first use of the Russia sanctions regime against Georgian media entities. (Source: OCCRP)

The European Union — The Missing Piece

The EU remains the most significant gap in the sanctions response.

As of March 2026, there is no EU Council decision imposing personal asset-freezing sanctions on Georgian individuals. The European Parliament has passed multiple resolutions calling for targeted sanctions — most recently in March 2026 following the OSCE Moscow Mechanism report — but these are non-binding political recommendations.

What the EU has done:

• January 27, 2025: Partially suspended visa-free travel for Georgian diplomats and officials.
• March 5–6, 2026: Extended the suspension to a broader category of officials under Schengen rules.
• Suspended Georgia’s EU accession process.

Why no personal sanctions? Council sanctions require consensus among member states. Some EU members reportedly resist imposing personal sanctions on Georgian officials, fearing it could push Tbilisi further toward Moscow. Others argue that the documented pattern of repression — comparable to Belarus in 2020 — demands an equivalent response.

The distinction matters: European Parliament resolutions recommend. The Council decides. Until the Council acts, EU sanctions on Georgian officials remain aspirational.

Baltic States and Ukraine

Baltic States (Estonia, Latvia, Lithuania)

On December 1–2, 2024, the three Baltic states jointly imposed national sanctions on 11 Georgian Dream-linked individuals — travel bans and asset freezes — in response to the violent suppression of protests. Adopted under each state’s national sanctions legislation but coordinated politically. The Baltic states were the first governments to sanction Georgian officials after the November 2024 crackdown. (Source: ERR News)

Ukraine

Ukraine has imposed sanctions on several Georgian figures, reportedly including Ivanishvili and associates, through RNBO (National Security and Defense Council) decrees. However, full official documentation of these designations is not readily accessible. GAP is working to verify the complete list.

The OSCE — Building the Evidence Base

The OSCE is not a sanctions body, but its mechanisms provide critical evidentiary foundations:

• Late 2024: Vienna Mechanism invoked by a group of OSCE participating states seeking clarification from Georgia on human rights abuses.
• January 29, 2026: 23 OSCE participating states invoke the Moscow Mechanism — a more serious investigative step.
• March 9, 2026: Rapporteur’s report finds “marked democratic backsliding,” “a pattern of violence and other abuses” against protesters, opposition leaders and journalists, sometimes reaching the threshold of torture, and highlights repressive legislation and attempts to ban opposition parties.

This report strengthens the legal and evidentiary case for expanded sanctions.

Individual Sanctions Matrix

*“Likely” = included in anonymous visa restriction rounds but name not published.*

Entity Sanctions

What the Sanctions Actually Do

Understanding the practical impact of each sanctions regime:

• OFAC SDN listing (US): All US-held assets frozen. No American citizen, company, or bank can do business with the designated person. Global banks routinely refuse service to SDN-listed individuals to avoid US secondary sanctions. This is the most powerful financial sanction available.
• Section 7031(c) (US): Public visa ban for the individual and immediate family. No asset freeze. Primarily a naming-and-shaming tool, but with real travel consequences.
• UK OFSI designation: UK-held assets frozen. Travel ban to the UK. Georgian banks are required by Georgian law to comply with US/EU/UK sanctions — meaning UK designations have direct effect on banking in Georgia itself.
• UK Russia regime (entities): Full financial freeze. For media companies like Imedi TV, this means frozen bank accounts, inability to pay staff through international banking, loss of Western broadcast partnerships and accreditation.
• Baltic national sanctions: Travel bans and sometimes asset freezes. Primarily symbolic but contribute to international isolation.
• EU visa-free suspension: Not a personal sanction but a category restriction removing visa-free Schengen access for certain officials. Enforcement at borders and consulates.

The Sanctions Gap — What’s Missing

Despite the expanding web of designations, critical gaps remain:

1. EU personal sanctions

The single biggest gap. Despite European Parliament resolutions, the Council has not acted. Georgia’s documented abuses — mass detention, torture, toxic chemical agents, media suppression, judicial capture — mirror the Belarus pattern that triggered comprehensive EU sanctions in 2020–2021. The EU’s inaction is a policy choice, not a legal limitation.

2. Key unsanctioned individuals

SSG (State Security Service) leadership remains untouched. Department of Special Assignments commanders beyond Kezevadze, additional members of the judicial “clan,” prosecutors who refused to investigate police violence, Alt-Info/Conservative Movement founders, and key GD MPs who drafted and voted for repressive legislation — all lack designations.

3. Sectoral sanctions

No country has imposed sectoral sanctions (arms embargo, technology restrictions, financial sector measures) on Georgia. Amnesty International called in December 2025 for “a complete embargo on all crowd-control equipment and related assistance to Georgian law enforcement” — no state has implemented this.

Amnesty’s call was partly prompted by evidence of chemical agent use in water cannons. Read “When Water Burns” →

4. Comparative gap

Georgia faces narrow personal sanctions. Belarus, after a similar pattern of election fraud and protest crackdown, faced comprehensive EU/US/UK sanctions including sectoral measures. Myanmar’s junta faces even broader restrictions. Georgia’s sanctions response is disproportionately mild relative to documented abuses.

The scale of those abuses is documented in our investigation of the December 2024 crackdown. Read “Anatomy of a Crackdown” →

The sanctions landscape is evolving. The March 2026 OSCE Moscow Mechanism report strengthens the evidentiary case for expanded designations. The UK’s February 2026 entity sanctions on Imedi TV and POSTV signal willingness to target the propaganda infrastructure, not just individuals.

But the critical question remains: will the European Union move from resolutions to action? GAP will continue to track every designation, maintain this sanctions matrix, and provide the evidence base that policymakers need. This page will be updated as new sanctions are imposed.