Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Global Magnitsky General Licenses 3 and 4?
OFAC's answer
No. Non-U.S. persons may engage in the transactions authorized for U.S. persons by[Global Magnitsky General License (GL) 3](https://ofac.treasury.gov/media/929866/download?inline) and wind down transactions with the blocked persons specified in [GL 4](https://ofac.treasury.gov/media/929871/download?inline), without exposure to sanctions under [Executive Order (E.O.) 13818](https://ofac.treasury.gov/media/8656/download?inline) or the Global Magnitsky Sanctions Regulations, 31 CFR part 583, provided that such activity is consistent with those GLs. Further, such transactions involving non-U.S. persons may be processed through the U.S. financial system or involve U.S. persons as long as the transactions comply with the terms and conditions in GLs 3 and 4. Non-U.S. persons unable to wind down transactions in accordance with GLs 3 and 4 before 12:01 a.m. eastern standard time, March 9, 2023, are encouraged to seek guidance from OFAC before that date.