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1101. What activity does Global Magnitsky General License 4 authorize?
On December 9, 2022, OFAC designated, pursuant to Executive Order (E.O.) 13818, several persons, including Dalian Ocean Fishing Co., Ltd.; Fujian Provincial Pingtan County Ocean Fishing Group Co., Ltd.; Fuzhou Honglong Ocean Fishing Co. Ltd.; and Pingtan Marine Enterprise Ltd. Concurrent with this action, OFAC issued Global Magnitsky General License (GL) 4, which authorizes all transactions ordinarily incident and necessary to the wind down of any transaction involving any vessel in which any of these blocked entities have an interest that would otherwise be prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583, through 12:01 a.m. eastern standard time, March 9, 2023, provided that any payment to a blocked person must be made into a blocked account in accordance with OFAC sanctions regulations.
The wind-down authorization in GL 4 contemplates, for example, completion...
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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...