OFAC FAQ (Current) # 1111 - Global Magnitsky Sanctions

Date issued: Jan. 26 2023

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TURBOFAC Commentary (76 words)

Notes:

1) Read in conjunction with Global Magnitsky General License 5. This FAQ generally restates the terms of the GL, and, in addition, clarifies that "[n]on-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in activities that would be exempt or authorized for U.S. persons pursuant to GL 5". Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).