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Case No CU-78815
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2003 Allende Avenue
The Villages, FL 32159
Dear Mr [ ]:
This responds to your letters dated April 6, 2009, July 15, 2011, and August 10, 2011, regarding the transfer of funds to relatives and family members in Cuba from estates that are blocked pursuant to the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "Regulations").
As you know, the Regulations, administered by the U.S. Department of the Treasury's Office of Foreign Assets Control, prohibit all persons subject to the jurisdiction of the United States from dealing in property in which Cuba or a Cuban national has an interest 31 CFR § 515.201. Section 515.570 of the Regulations authorizes by general license the transfer of certain remittances to nationals of Cuba, subject...
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1) 515.570(f) – Heirs to Heirs
While the remittance forwarding aspects of this guidance letter relate to provision of the CACR that have liberalized since the 2012 issuance of the letter, the guidance letter interprets language in 515.570(f) that tracks what appears in that section of the CACR as of 12-20-23. More specifically, OFAC determines that for purposes of the GL authorizing remittances from blocked accounts “in the United States held in the name of, or in which the beneficial interest is held by, a national of Cuba as a result of a valid testamentary disposition,” remittances may, in principle and depending on the determinations of a U.S. probate court, be made to the heirs of the original heir in which whose name an account is opened.
2) As...