Case No. CU-2015-319798-1

Date issued: Sep. 18 2018

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TURBOFAC Commentary (383 words)

Notes:

1) As of the date on which this letter was issued, the CACR authorized “all transactions incident to joint medical research projects with Cuban nationals” (515.547(a)) and 515.590 authorized “provision of grants, scholarships, or awards relating to [educational activities and scientific research] to a Cuban national or in which Cuba or a Cuban national otherwise has an interest…” Both GLs are still in effect as of 12-21-23.

Given that the request is for “the importation of medical specimens from Cuba and to exchange services with Cuban entities incident to medical research and collaboration” and that the request for a license was returned without action, it is likely that OFAC regards “importation of medical specimens from Cuba” as a transaction that can be “incident to joint medical research projects with Cuban nationals.” Given the breadth...