Case No. CU-2014-309068-1, CU-2015-317611-1

Date issued: Jun. 21 2018

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (322 words)

Notes:

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...