Case No. CU-2022-895293-1

Date issued: May. 22 2025

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TURBOFAC Commentary (428 words)

Notes:

1) Compare Case No. CU-2015-319004-1, a similar letter discussing the scope of the carrier services GL and transactions ordinarily incident thereto. Here, the applicant is a “U.S.-based travel and charter service provider headquartered in Miami”. 515.572 authorizes “[p]ersons subject to U.S. jurisdiction…to provide carrier services to, from, or within Cuba in connection with travel or transportation, directly or indirectly, between the United States and Cuba of persons, baggage, or cargo authorized pursuant to” the CACR, and 515.421 authorizes all transactions ordinarily incident to licensed transactions. Separately, 515.564 authorizes travel-related transactions “directly incident to attendance at, or organization of, professional meetings or conferences in Cuba” and 515.533 authorizes “transactions ordinarily incident to the exportation of items from the United States, or the reexportation of items from a third country, to...