PolicyBrief
H.R. 5369
119th CongressSep 15th 2025
Azerbaijan Sanctions Review Act of 2025
IN COMMITTEE

This Act mandates the President to review specific Azerbaijani officials for potential U.S. sanctions based on findings of human rights abuses, forced displacement, and mistreatment of detainees.

Dina Titus
D

Dina Titus

Representative

NV-1

LEGISLATION

New Act Mandates Review of 53 Azerbaijani Officials for Human Rights Sanctions Within 180 Days

This new piece of legislation, the Azerbaijan Sanctions Review Act of 2025, isn't about setting up new sanctions right now. It’s about forcing a detailed, time-bound review of key officials in Azerbaijan to see if they should face sanctions under existing U.S. law. Think of it as Congress handing the President a very specific homework assignment with a firm deadline.

The Mandate: A 180-Day Deadline for Accountability

What this bill does is simple and direct: It requires the President to investigate 53 named individuals from the Azerbaijani government and military. The goal is to determine if these people meet the criteria for sanctions under two powerful accountability tools already on the books: the Global Magnitsky Human Rights Accountability Act or Section 7031(c) of the appropriations law. Both laws target foreign officials involved in serious human rights abuses or corruption. The President has exactly 180 days after this Act becomes law to complete this review and report the findings back to six key congressional committees, including those overseeing foreign policy and finance.

Why the Review? The Allegations Driving the Bill

To understand why Congress is pushing this, you have to look at the "Findings" section (Sec. 2), which reads like a detailed indictment. It cites extensive allegations of war crimes and human rights abuses following Azerbaijan’s 2023 military action in Nagorno-Karabakh, which led to the forced displacement of the entire ethnic Armenian population. The bill points to allegations of extrajudicial killings, torture of prisoners of war (POWs), and the illegal detention of political figures like former officials Ruben Vardanyan and Arayik Harutyunyan, who are reportedly undergoing “sham trials” without proper legal rights. Essentially, Congress is saying: We've seen these reports of severe abuses and violations of international law, and now we need to see if the individuals allegedly responsible meet the legal threshold for U.S. sanctions.

Who’s On the Hot Seat?

The list of 53 individuals the President must review is highly specific, targeting the upper echelons of power. It includes high-ranking military commanders like Lieutenant General Hikmat Izzat oglu Mirzayev (Commander of the Special Forces), the Chief of the State Security Services, and various prosecutors and judges from the Baku Court on Grave Crimes. If you’re one of these named officials, this bill means your financial assets and travel to the U.S. are now under intense scrutiny. Sanctions, if applied, could mean asset freezes and visa bans, effectively limiting your ability to use the global financial system.

The Real-World Impact of a Sanctions Review

For the average person in the U.S., this bill primarily signals a strong shift in foreign policy priorities, emphasizing human rights accountability over diplomatic silence. For the victims and their families—especially the estimated 100,000 displaced Armenians and the families of the detained political prisoners—this bill represents a concrete step toward international pressure for justice and the release of those illegally held. The immediate impact is procedural, but the long-term goal is to use U.S. financial muscle to enforce international norms. This move also puts the Azerbaijani government on notice that its alleged internal crackdown—including the detention of over 300 journalists and activists—is being watched closely, especially ahead of major international events like the upcoming COP29 Climate Summit.