Case No. CU-2016-332180-1

Date issued: Aug. 13 2018

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TURBOFAC Commentary (648 words)

Notes:

1) Compare Case No. CU-2016-337943-1 and Case No. CU-2016-334368-1, which are other guidance letters citing the GL (515.534) authorizing the negotiation of, and entry into, contingent contracts, and travel to Cuba for the purposes of the same.

2) This case and Case No. CU-2016-337943-1 are similar in that they both involve U.S. person providers of information-related services in the travel industry, and OFAC says “Note that the general licenses at sections 515.534 and 515.564 exclude direct financial transactions prohibited at section 515.209. [] The potential business subject to these negotiations may also be prohibited by this provision.” This appears aimed at conveying that while the general licenses for negotiation and negotiation-related travel do not themselves authorize transactions otherwise prohibited by 515.209, the negotiation of potential future transactions prohibited by 515.209 are authorized by...