OFAC FAQ (Current) # 1100 - Global Magnitsky Sanctions

Date issued: Dec. 09 2022

Last substantive commentary amendment:
Jun. 15 2023

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TURBOFAC Commentary (603 words)

Notes:

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...