LICENSE No. CU-2018-353672-3

Date issued: Sep. 16 2021

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TURBOFAC Commentary (142 words)

Notes:

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...