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Case No. CU-2014-309068-1, CU-2015-317611-1
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[ ]
1101 Seventeenth Street, NW Suite 1100
Washington, DC 20036
Dear [ ]:
This responds to your requests, on behalf of the World Trade Centers Association (WTCA), dated April 24, 2014 and March 19, 2015, and additional correspondence dated August 5, 2014, January 6, 2017, and January 13, 2017, to the Office of Foreign Assets Control (OFAC).
WTCA seeks the following:
1) authorization for the release of $120,000 in cash, comprising membership dues paid to WTCA by Havana World Trade Center (“WTC Havana”), a WTCA member organization, currently held in a blocked account with HSBC Commercial Bank in New York, New York (“HSBC Account”), plus interest;
2) authorization or an interpretive ruling permitting WTCA’s relations with WTC Havana, including WTCA’s receipt of additional dues payments from WTC Havana;
3) authorization for the “unblocking” of a 1986 trademark-license...
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1) Membership as Exempt
With respect to the applicants' request to "provide membership services to WTC Havana" OFAC cites the exemption at 515.206 of the CACR to conclude that "[t]o the extent that [U.S. persons'] membership includes access to exempt information or other informational materials under the CACR, such services would not require additional authorization from OFAC." See General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note), and compare 031103-FACRL-IA-15, which OFAC cites in this letter. From a procedural standpoint, it is notable that OFAC cites 031103-FACRL-IA-15 as it if were still “good law,” notwithstanding that it was removed from OFAC’s website and notwithstanding that it related to a difference sanctions program. As discussed in General Background Note on the Chronology of...