License No. CU-79885 [Application in PDF file]

Date issued: Jul. 12 2010

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TURBOFAC Commentary (1674 words)

Notes:

1) BACKGROUND

1.1) The Legal Services GL and Related Licensing Policy for the Receipt of Payments

At all relevant times, 515.512 of the CACR contained a legal services GL stating that "[t]he provision of the [specified types of] legal services to or on behalf of Cuba or a Cuban national is authorized, provided that all receipts of payment of professional fees and reimbursement of incurred expenses must be specifically licensed..." This "to or on behalf of" language is standard in all modern standard legal services GLs. The five types of services authorized are those found in modern standard legal services GLs that appear on a cross-programmatic basis (one of which includes "Provision of legal advice and counseling on the requirements of and compliance with the laws of the United States or any jurisdiction...