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1100. I am a U.S. person that owns debt or equity, including publicly traded shares, in Pingtan Marine Enterprise, Ltd. (PME), which was designated under Executive Order (E.O.) 13818.  What actions am I authorized to take under Global Magnitsky General License 3?  

Answer

Pursuant to Global Magnitsky General License (GL) 3, U.S. persons are authorized to engage in certain transactions that would otherwise be prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583, ordinarily incident and necessary to the divestment or transfer, or facilitation of the divestment or transfer, of debt or equity of PME to a non-U.S. person through 12:01 a.m. eastern standard time, March 9, 2023.  

GL 3 also authorizes transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of debt or equity of PME that were placed prior to 4:00 p.m. eastern standard time, December 9, 2022, through 12:01 a.m. eastern standard time, March 9, 2023.  

GL 3 also authorizes, through 12:01 a.m. eastern standard time, March 9, 2023, transactions ordinarily incident and necessary to the wind down of financial contracts or other agreements linked to the debt or equity of PME and entered into prior to 4:00 p.m. eastern standard time, December 9, 2022, provided that any payments to a blocked person are made into a blocked account in accordance with OFAC sanctions regulations.  This authorization includes transactions ordinarily incident and necessary to the delisting of PME from a U.S. securities exchange. 

However, GL 3 does not authorize U.S. persons to sell or facilitate the sale of debt or equity of PME to, directly or indirectly, any person whose property and interests in property are blocked, including Xinrong Zhuo, who was designated on the same day and is PME’s chairman and CEO, among other things.  U.S. persons unable to wind down transactions in accordance with GL 3 before 12:01 a.m. eastern standard time, March 9, 2023, are encouraged to seek guidance from OFAC before that date.  Please see GL 3 for further details.  

Date Released
December 9, 2022