Global Magnitsky Sanctions

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Frequently Asked Questions

OFAC has compiled hundreds of frequently asked questions (FAQs) about its sanctions programs and related policies. The first link below sends the user to Global Magnitsky-specific FAQs, the subsequent link to  the entire list of OFAC's FAQs.

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. 

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.

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.

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 public laws (statutes) passed by The Congress.

Executive Orders

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

Statutes

Code of Federal Regulations

Federal Register Notices

  • 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”).