1191. On September 12, 2024, OFAC designated Ly Yong Phat (Ly), L.Y.P. Group Co., LTD (L.Y.P. Group), and the following entities owned by L.Y.P. Group under the Global Magnitsky sanctions authority: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. Can I continue to engage in transactions or other dealings with other entities owned by Ly or L.Y.P. Group that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

Yes. Although transactions or other dealings involving Ly and L.Y.P. Group are prohibited as a result of OFAC's designation, OFAC concurrently issued Global Magnitsky General License (GL) 8 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ly or the L.Y.P. Group that is not listed on SDN List.

Non-U.S. persons may engage in the transactions authorized by GL 8 without exposure to sanctions.

GL 8 does not authorize transactions with any entity listed on the SDN List, including the following entities that were designated on September 12, 2024: O-Smach Resort, Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel. OFAC will continue to closely monitor Ly's and L.Y.P. Group's activities and may designate or identify additional entities, as appropriate.