OFAC - Global Magnitsky General License 2 - Authorizing Certain Wind Down and Divestment Transactions and Activities Related to Blocked Subsidiaries of the Xinjiang Production and Construction Corps (XPCC)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

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TURBOFAC Commentary (236 words)

Notes:

1) With the exceptions described below, this is a normal entity-specific "wind down" general license. Compare Global Magnitsky General License 1A and see the related FAQ, issued on the same day at the , at FAQ # 835.

2) The GL is irregular insofar as it only covers transactions with entities blocked pursuant to the 50% rule as a result of their ownership by the at issue, instead of all transactions with the SDN plus any entities blocked pursuant to the 50% rule as a result of their ownership by the SDN at issue.

The GL is also irregular insofar as it contains a separate "divestment" and securities-related GL, that operates in addition to the wind-down portion at paragraph (a). Paragraph (b) specifies that U.S. persons may “facilitate the transfer of debt, equity, or other holdings in any Blocked XPCC Subsidiary by a non-U.S. person to another non-U.S. person…” These authorizations apply irrespective of whether or not they directly involve any “Blocked XPCC Subsidiary”—they normally would not—and apply independent of the question of whether the securities-related transaction at issue would otherwise fall within the scope of the “wind down” language.

3) License amended on 9-25-2020 to extend the expiration date.

4) Refer generally to General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers.

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Global Magnitsky General License 2A (Expired)- Authorizing Certain Wind Down and Divestment Transactions and Activities Related to Blocked Subsidiaries of the Xinjiang Production and Construction Corps (XPCC)​

TURBOFAC Commentary (236 words)

Global Magnitsky General License 2A (Expired)- Authorizing Certain Wind Down and Divestment Transactions and Activities Related to Blocked Subsidiaries of the Xinjiang Production and Construction Corps (XPCC)