  We study the virtual Compton amplitude in the generalized Bjorken region (q^2
-> Infinity, t small) in QCD by means of a light-cone expansion of the product
of e.m. currents in string operators in coordinate space. Electromagnetic gauge
invariance (transversality) is maintained by including in addition to the
twist-2 operators 'kinematical' twist-3 operators which appear as total
derivatives of twist-2 operators. The non-forward matrix elements of the
elementary twist-2 operators are parametrized in terms of two-variable spectral
functions (double distributions), from which twist-2 and 3 skewed distributions
are obtained through reduction formulas. Our approach is equivalent to a
Wandzura-Wilczek type approximation for the twist-3 skewed distributions. The
resulting Compton amplitude is manifestly transverse up to terms of order
t/q^2. We find that in this approximation the tensor amplitude for longitudinal
polarization of the virtual photon is finite, while the one for transverse
polarization contains a divergence already at tree level. However, this
divergence has zero projection on the polarization vector of the final photon,
so that the physical helicity amplitudes are finite.
