Case No. CU-2015-323083-1

Date issued: Jul. 25 2017

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TURBOFAC Commentary (366 words)

Notes:

1) The application was initially filed on August 31, 2015. On January 16, 2015, OFAC amended 515.572 such that persons subject to U.S. jurisdiction no longer needed to have status as authorized “travel service providers” in order to provide travel-related services. The GL, as amended on January 16, 2015, provided that “Persons subject to U.S. jurisdiction are authorized to provide travel services in connection with travel-related transactions involving Cuba authorized pursuant to this part.” (see 80 FR 2299, Jan. 16, 2015). It is not clear precisely what the applicant was requesting authorization for, but in any event OFAC makes clear that 515.572 can cover “the provision of travel services for persons subject to U.S. jurisdiction traveling from third countries to Cuba for purposes covered by the Cuban travel general licenses.” In other words, the GL covers (say) travel agents to book...