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Case No. CU-2015-320741-1
October 7, 2015
Royal Caribbean Cruises Ltd.
c/o Holland & Knight LLP
800 17th Street, NW, Suite 1100
Washington, DC 20006
Attn: Mr. Ronald Oleynik
Subject: Your Vessel Carrier Services Application
Dear Mr. Oleynik:
October 7, 2015
This responds to your license application dated July 17, 2015, which you submitted to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), requesting authorization to provide carrier services by vessel involving Cuba.
The Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "Regulations"), administered by OFAC, prohibit persons subject to the jurisdiction of the United States from dealing in property in which Cuba or a Cuban national has an interest, unless exempt or authorized by OFAC.
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1) Background
At the time the license applications assigned Case No. CU-2015-320741-1 and Case No. CU-2015-320507-1 were made, 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. [1]
[1] https://www.govinfo.gov/content/pkg/FR-2015-01-16/pdf/2015-00632.pdf#page=9
The license application was made just prior to 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 such vessels...