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LICENSE No. CU-2018-353672-3
CUBAN ASSETS CONTROL REGULATIONS
LICENSE RENEWAL
(Issued under the authority one or more of 50 U.S.C. § 4305(b), 22 U.S.C. § 2370(a), 22 U.S.C. §§ 6001 et seq., Proclamation 3447, and 31 C.F.R. Parts 501 and 515)
To: Volando, Inc. d/b/a Volando.US c/o KMA Zuckert LLC
888 17th Street, N.W.
Suite 700
Washington DC, 20006
Attn: Lonnie Anne Pera, Esq.
1. Based upon your request on behalf of Volando, Inc. d/b/a Volando.US, dated May 24, 2021 to U.S. Department of the Treasury’s Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized. This license supersedes License No. CU-2018-353672-2 in all respects.
2. This License is subject to the condition, among others, that the Licensee(s) comply in all respects with its...
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1) Highly unusual specific license, notable for the licensing policy not otherwise evident from OFAC's regulations, allowing an entity with no apparent internet presence to charter flights between Havana and Guyana for the sole purpose of allowing "Cuban national passengers who self-report that their travel is for the purpose of attending consular services appointments at the U.S. embassy" to fly in between Havana and Guyana.
2) Implicit in the license is a limitation on the scope of the "official business" GL (here 515.562). Flying people to a U.S. embassy is not ordinarily incident to the "official business" of the USG (i.e. the State Department that runs the embassy). If the Licensee had a contract with the State Department or some other binding agreement that could constitute a contract, the "official business" GL would...