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Case No. CU-82413
Korea Pyongyang Trading USA, Inc.
98 Thayer Street, #1B
New York, NY 10040
Attn: Il Woo Park
Dear Mr. Park:
This is in response to your letter dated January 26, 2012 (the “Application"), to the Office of Foreign Assets Control ("OFAC") on behalf of Korea Pyongyang Trading USA, Inc. ("KPT"), a company based in New York, NY, requesting an advisory opinion as to whether a specific license is required to purchase glass eels, a seafood product, from Cuba for shipment from Cuba to a third country, Panama.
The transactions you describe are governed by the Cuban Assets Control Regulations, 31 C.F.R. Part 515 ("the Regulations"), which prohibit persons subject to the jurisdiction of the United States from engaging in transactions in which Cuba or a Cuban national has an interest unless authorized...
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1) The letter is a bit dated at this point, but is notable for OFAC having said that there was "no precedent to issue a specific license to authorize the purchase of any product from Cuba for shipment to a party in a third country." Given the age of the CACR, "no precedent" with respect to any proposition is notable. For licensing policy purposes, it would be safe to say that requests for such transactions come with a very strong presumption of denial.