Case No. CU-2015-319004-1

Date issued: Jul. 02 2015

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TURBOFAC Commentary (1733 words)

Notes on Case No. CU-2015-319004-1 and License No. CU-2015-319004-1.

1) BACKGROUND

At the time the letter (pp. 1-2) and license (pp.3-5) were issued, 515.572(a)(2) of the CACR provided as follows:

(2) Authorization to provide carrier services. Persons subject to U.S. jurisdiction are authorized to provide carrier services by aircraft to, from, or within Cuba in connection with travel or transportation to Cuba of persons, baggage, or cargo authorized pursuant to this part. (https://www.govinfo.gov/content/pkg/FR-2015-01-16/pdf/2015-00632.pdf#page=9).

The license was issued not long before the September 21, 2015 addition to the CACR of 515.572(a)(4), which read as follows:

(4) Authorization to provide lodging services. Persons subject to U.S. jurisdiction who are providing carrier services by vessel authorized pursuant to paragraph (a)(2) of this section are authorized to provide lodging services onboard...