Case No. CT-2015-320135-1

Date issued: Jul. 02 2015

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TURBOFAC Commentary (299 words)

Notes:

1) Compare Case No. CU-2013-300818-4 and Case No. CU-2013-300818-5 (same applicant). The applicant here is an attorney who was frequently appointed by a Florida probate court to serve as an Attorney Ad Litem to represent the interest of Cuban national heirs to estates subject to probate in the U.S. Attorneys on the so-called “Attorney Ad Litem Wheel” frequently travel to Cuba in connection with such representation, including for the purpose of obtaining various consents from the Cuban heirs. Compare also Case No. CU-73511.

The representation as Attorney Ad Litem is evidently authorized by 515.523 of the CACR (see Case No. CU-2013-300818-4). What about travel to Cuba in connection with such generally authorized representation? Here, OFAC responds to a request for travel to Cuba in connection with an...