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Case No. CU-2016-337943-1
Doreen M. Edelman
Baker, Donelson, Bearman,
Caldwell & Berkowitz, P.C.
901 K Street, NW
Washington, DC 20001
Dear Ms. Edelman:
This is in reply to your November 29, 2016 request, on behalf of STR, Inc., to the Office of Foreign Assets Control (OFAC) for a specific license authorizing STR to enter agreements with the Ministry of Tourism of Cuba and hotels in Cuba to provide competitive benchmarking, information services, and research products regarding the global hotel industry and to provide those services. STR also proposes to obtain hotel information from the Cuban government and host a conference in Cuba to market its services. STR has not yet concluded such agreements or provided related services.
The Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR), prohibit persons subject to...
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1) Compare Case No. CU-2016-332180-1 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) RECEIPT/CREATION OF INFORMATIONAL MATERIALS FOR PRESUMABLY FOR FURTHER COMMERCIAL EXPLOITATION
The applicant entity here, STR, Inc., is essentially the hotel equivalent of the Airline Tariff Publishing Company that is the subject of Case No. MUL-372-1. Both are data-focused industry clearinghouses for information related to the hotel and airline industries; both solicit data from hotels/airlines worldwide and make such data available to their subscribers for a fee.
Here, STR seeks to "obtain hotel information from the Cuban government," i.e. a "list of hotels in Cuba from the Ministry of Tourism...