On January 26, 2023, OFAC designated, pursuant to E.O. 13818, Horacio Manuel Cartes Jara (Cartes) for his involvement in corruption in Paraguay.  Also on that day, OFAC designated four entities owned or controlled by Cartes, pursuant to E.O. 13818:  Tabacos USA Inc., Bebidas USA Inc., Dominicana Acquisition S.A., and Frigorifico Chajha S.A.E. (collectively, “designated Cartes entities”).  Concurrent with this action, OFAC issued Global Magnitsky General License (GL) 6 , which authorizes, subject to certain conditions, transactions prohibited by the Global Magnitsky Sanctions Regulations, 31 CFR part 583 (GMSR), that are ordinarily incident and necessary to the wind down of any transaction involving any of the designated Cartes entities, or any entity in which Cartes or the designated Cartes entities own, directly or indirectly, a 50 percent or greater interest (collectively, “blocked Cartes entities”), through 12:01 a.m. eastern daylight time, March 27, 2023, provided that any payment to a blocked person must be made into a blocked account in accordance with the GMSR.  GL 6 does not authorize any transactions involving Cartes himself.

After the expiration of this general authorization, U.S. persons will be prohibited from engaging in such wind-down transactions with blocked Cartes entities, unless exempt or otherwise authorized by OFAC.  U.S. persons unable to wind down transactions with blocked Cartes entities before 12:01 a.m. eastern daylight time, March 27, 2023, are encouraged to seek guidance from OFAC.

Non-U.S. persons may wind down transactions with blocked Cartes entities without exposure to sanctions under E.O. 13818, provided that such wind-down activity is consistent with GL 6.  Wind-down 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 GL 6.  Non-U.S. persons unable to wind down transactions with blocked Cartes entities before 12:01 a.m. eastern daylight time, March 27, 2023, are encouraged to seek guidance from OFAC.

On January 26, 2023, OFAC designated Frigorifico Chajha S.A.E. (Frigorifico Chajha), pursuant to E.O. 13818.  Concurrent with this action, OFAC issued General License (GL) 5 , which authorizes certain transactions ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity of Frigorifico Chajha to a non-U.S. person, through 12:01 a.m. eastern daylight time, March 27, 2023.  

GL 5 also authorizes certain transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of debt or equity of Frigorifico Chajha that were placed prior to 4:00 p.m. eastern standard time, January 26, 2023, through 12:01 a.m. eastern daylight time, March 27, 2023.  

GL 5 also authorizes certain transactions that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, January 26, 2023, that (1) include Frigorifico Chajha as a counterparty, or (2) are linked to the debt or equity of Frigorifico Chajha, through 12:01 a.m. eastern daylight time, March 27, 2023, provided that any payments to a blocked person are made into a blocked account in accordance with the Global Magnitsky Sanctions Regulations, 31 CFR part 583.  

However, GL 5 does not authorize U.S. persons to sell, or to facilitate the sale of, debt or equity of Frigorifico Chajha to, directly or indirectly, any person whose property and interests in property are blocked.  GL 5 also does not authorize U.S. persons to purchase or invest in, or to facilitate the purchase of or investment in, directly or indirectly, debt or equity of Frigorifico Chajha, other than purchases of or investments in debt or equity of Frigorifico Chajha that are ordinarily incident and necessary to the divestment or transfer of debt or equity of Frigorifico Chajha as described in GL 5.

Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in activities that would be exempt or authorized for U.S. persons pursuant to GL 5.