OFAC FAQ (Current) # 1101 - Global Magnitsky Sanctions

Date issued: Dec. 09 2022

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TURBOFAC Commentary (426 words)

Notes:

1) Read in conjunction with Global Magnitsky General License 4. This FAQ is similar to other FAQs (see e.g. FAQ # 817) addressing designations of individual entities that were made in conjunction with the issuance of a wind-down license, but the FAQ is notable for its clarification of the relationship between the language of the "wind down" GL and dealings involving blocked vessels.

OFAC states that the following are within the scope of the GL:

"...for example, completion of ongoing voyages, including the discharge of cargo aboard such vessels to non-blocked persons; docking or anchoring of the vessels at third-country, non-sanctioned ports; transactions related to the safety and maintenance of such vessels, such as entering into certain contracts to pay for insurance coverage, flagging, and safety and compliance inspections during the wind-down period; and transactions related...