Global Magnitsky General License 8 - Authorizing Transactions Involving Certain Entities Owned by Ly Yong Phat or L.Y.P. Group Co., LTD (September 12, 2024)

Date issued: Sep. 12 2024

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TURBOFAC Commentary (212 words)

Notes:

1) Compare (now revoked) Russia-related GL 15, similarly authorizing transactions with non-SDN entities owned by an individual on the SDN list. The GL effectively "undoes" what would otherwise be the effect of the 50% rule as it relates to certain entities that are blocked by operation of law due to 50% or greater ownership by Ly Yong Phat or L.Y.P. Group Co., LTD. The entities are technically blocked by operation of law, but the GL authorizes all transactions otherwise prohibited as a result of the 50% rule.

2) See FAQ # 1191, issued concurrently.

3) Russia GL 15 had a provision that read as follows:

“(c) This general license does not authorize any transactions otherwise prohibited by the RuHSR...