Global Magnitsky Sanctions

Frequently Asked Questions

OFAC has compiled hundreds of frequently asked questions (FAQs) about its sanctions programs and related policies. The links below send the user to OFAC's FAQ pages.

Interpretive Guidance

OFAC issues interpretive guidance on specific issues related to the sanctions programs it administers. These interpretations of OFAC policy are sometimes published in response to a public request for guidance or may be released proactively by OFAC in order to address a complex topic.

Index of Interpretative Guidance

Applying for a Specific OFAC License

It may be in your and the U.S. government’s interest to authorize particular economic activity related to the Global Magnitsky Sanctions. Visit the link below to apply for an OFAC license.

Apply for an OFAC License Online - Authorization from OFAC to engage in a transaction that otherwise would be prohibited.

Guidance on OFAC Licensing Policy

Certain activities related to the Global Magnitsky Sanctions may be allowed if they are licensed by OFAC. Below OFAC has issued guidance and statements on specific licensing policies as they relate to the Global Magnitsky Sanctions.

Licenses for Legal Fees and Costs - Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs Incurred in Challenging the Blocking of U.S. Persons in Administrative or Civil Proceedings
Entities Owned By Blocked Persons - Guidance On Entities Owned By Persons Whose Property And Interests In Property Are Blocked

General Licenses

OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to the Global Magnitsky sanctions program. General licenses allow all US persons to engage in the activity described in the general license without needing to apply for a specific license.

Global Magnitsky General License 3 - Authorizing Transactions Related to Debt or Equity of Pingtan Marine Enterprise Ltd. (December 09, 2022)
Global Magnitsky General License 4 - Authorizing the Wind Down of Transactions Involving Certain Vessels (December 09, 2022)
Global Magnitsky General License 5 - Authorizing Certain Transactions Related to Frigorifico Chajha S.A.E. (January 26, 2023)
Global Magnitsky General License 6 - Authorizing the Wind Down of Transactions Involving Bebidas USA Inc., Tabacos USA Inc., Frigorifico Chajha S.A.E., Dominicana Acquisition S.A., or Certain Blocked Entities Owned by Horacio Manuel Cartes Jara (January 26, 2023)
Global Magnitsky General License 7 - Authorizing Certain Transactions Involving Tabacalera del Este S.A. or Tabacos USA Inc. Pursuant to the Tobacco Master Settlement Agreement (March 31, 2023)
Archive of Expired General Licenses

Press Charts

OFAC press charts relating to the players in and structures of corruption networks.

2019 Press Charts

Sandoval Castaneda Network

Legal Framework for the Global Magnitsky Sanctions

The Global Magnitsky Sanctions program represents the implementation of multiple legal authorities. Some of these authorities are in the form of an executive order issued by the President. Other authorities are public laws (statutes) passed by The Congress. These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR). Modifications to these regulations are posted in the Federal Register.

Executive Orders

13818 Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption (Effective Date - December 21, 2017)

Statutes

Suspending Normal Trade Relations with Russia and Belarus Act - Public Law 117–110
Global Magnitsky Human Rights Accountability Act 22 U.S.C. 2656 note - Public Law 114-328
International Emergency Economic Powers Act (IEEPA), 50 U.S.C. §§ 1701-1706

Code of Federal Regulations

31 CFR Part 583 - Global Magnitsky Sanctions Regulations

Federal Register Notices

89 FR 17728-24 - Publication of Amended Global Magnitsky Sanctions Regulations
88 FR 64380-23 - Publication of Global Magnitsky Sanctions Regulations Web General Licenses 1, 2, and Subsequent Iterations
88 FR 31475-23 - Publication of Global Magnitsky Sanctions Regulations Web General License 7
88 FR 2522-23 - Publication of Global Magnitsky Sanctions Regulations Web General Licenses 3 and 4
88 FR 11815-23 - Publication of Global Magnitsky Sanctions Regulations Web General Licenses 5 and 6
87 FR 78484-22 - Publication of Humanitarian Sanctions Regulations Amendment and General Licenses (Nongovernmental Organizations, Agricultural, and Medicine)
87 FR 78470-22 - Publication of United States Government and International Organizations Official Business Sanctions Regulations Amendment and General Licenses
83 FR 30541-18 - Implementation of the Global Magnitsky Human Rights Accountability Act and Executive Order 13818 of December 20, 2017 (“Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption”).