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1100. I am a U.S. person that owns debt or equity, including publicly traded shares, in Pingtan Marine Enterprise, Ltd. (PME), which was designated under Executive Order (E.O.) 13818. What actions am I authorized to take under Global Magnitsky General License 3?
Pursuant to Global Magnitsky General License (GL) 3, U.S. persons are authorized to engage in certain transactions that would otherwise be prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583, ordinarily incident and necessary to the divestment or transfer, or facilitation of the divestment or transfer, of debt or equity of PME to a non-U.S. person through 12:01 a.m. eastern standard time, March 9, 2023.
GL 3 also authorizes transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of debt or equity of PME that were placed prior to 4:00 p.m. eastern standard time, December 9, 2022, through...
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1) Read in conjunction with Global Magnitsky General License 3. The purpose of this FAQ, which otherwise reiterates what is found in the GL, appears to be to clarify that the GL does not authorize transactions involving the SDN chairman and CEO of the blocked entity. Implicitly it is clear that that individual does not necessarily have an "interest" in transactions involving debt and equity of the entity. Compare FAQ # 398 and FAQ # 400.
2) *Note Common to FAQ # 807, FAQ # 835, FAQ # 841, FAQ # 883, FAQ # 1102 and FAQ # 1112
FAQ # 835, FAQ # 841, FAQ # 883, FAQ # 1102 and FAQ # 1112 all stand for the notable...