Global Magnitsky General License 4 - Authorizing the Wind Down of Transactions Involving Certain Vessels (December 09, 2022)

Date issued: Dec. 09 2022

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TURBOFAC Commentary (197 words)

Notes:

1) Read in conjunction with FAQ # 1101, clarifying the scope of the standard "wind down" language found here, as it relates in particular to blocked vessels.

2) Compare Venezuela General License 37 (similar now-revoked GL issued in the Venezuela context), with the primary differences being that (i) this GL contains OFAC's now-standard restriction concerning payments to blocked persons, and (ii) the Venezuela GL authorized dealings involving certain "persons or vessels" (i.e. the vessels and their owners), while this GL authorizes transactions "involving any vessel in which any of the [specified] blocked entities have an interest". It is implied that the license authorizes against the prohibitions

3) As with the Venezuela GL and (and GTSR General License 21), there is a carveout in the GL that says that it does...