Global Magnitsky General License 3 - Authorizing Transactions Related to Debt or Equity of Pingtan Marine Enterprise Ltd. (December 09, 2022)

Date issued: Dec. 09 2022

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TURBOFAC Commentary (276 words)

Notes:

1) Read in conjunction with FAQ # 1100, issued concurrently with this GL.

2) Compare Russia-related General License 48. This is, as of 12-2022, a standard GL for the genre. The primary substantive differences between this GL and Russia-related GL 48 are (i) Note to paragraph (c) specifying that "[t]he wind down of financial contracts or other agreements linked to the debt or equity of PME includes the delisting of PME from a U.S. securities exchange," and (ii) the fact that the GL is limited to " debt or equity of" the SDN, rather than the SDN plus any entity blocked by operation of law due to 50% or greater ownership by the SDN. It is not clear whether and in what circumstances debt issued by a different entity...