OFAC FAQ (Current) FAQ # 1191 -Global Magnitsky Sanctions

Date issued: Sep. 12 2024

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TURBOFAC Commentary (136 words)

Notes:

1) See comments to Global Magnitsky General License 8. The primary purpose of the GL is (consistent with FAQ # 7) to assure non-U.S. persons that “Non-U.S. persons may engage in the transactions authorized by GL 8 without exposure to sanctions” (or, as put in FAQ # 7, “non-U.S. persons do not generally risk being sanctioned for engaging in or facilitating transactions for which a U.S. person would not require a specific license.” Concerning the statement that “transactions or other dealings involving Ly and L.Y.P. Group are prohibited as a result of OFAC's designation,” query whether such dealings are authorized if ordinarily incident to an otherwise authorized transaction with a subsidiary. Probably not, but the wording of the license, particularly in light of comparison to Russia GL 15, leaves some ambiguity on that point.