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NOV 8 2004
Case No. CU-73511
Enrique Zamora, Esq.
Zamora & Hillman
3006 Aviation Avenue
Penthouse 4C
Coconut Grove, FL 33133
Dear Mr. Zamora:
This response to your letters of August 11, 2003, January 30, 2004, June 28, 2004, and August 17, 2004, concerning a proposed procedure for the debit of quarterly remittances from Cuban blocked accounts at financial institutions and transfer of the funds to beneficiaries in Cuba via remittance forwarding companies. As you know, the Cuban Assets Control Regulations, 31 C.F.R Part 515 (the “Regulations”), which are administered by the Office of Foreign Assets Control (“OFAC”), prohibit all dealings by persons subject to the jurisdiction of the United States in property in which Cuba or a Cuban national has an interest, including transfers to Cuban beneficiaries, unless licensed or otherwise...
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1) The guidance letter at p. 12 of the native PDF file is addressed to an attorney who was frequently appointed by a Florida probate court as a “Guardian Ad Litem” to represent the interests of blocked Cuban nationals in probate cases in which they would be entitled to assets from U.S.-based estates. At the time this guidance letter was issued, 515.570 of the CACR provided (in relevant part) as follows:
§ 515.570 Remittances to nationals of Cuba.
(a) Periodic $300 family household remittances authorized. Persons subject to the jurisdiction of the United States who are 18 years of age or older are authorized to make remittances to nationals of Cuba who are members of the remitter's immediate family, provided that:
(1) The remitter's total remittances do not exceed $300 per recipient household in any consecutive 3-month period, regardless...