Case No. CU-2015-315858-1

Date issued: Feb. 03 2017

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TURBOFAC Commentary (625 words)

Notes:

1) BACKGROUND

The applicant, which open-source research shows to be a small electrical/network cabling contractor, requests authorization to “analyze, identify, propose, and/or deploy low cost solutions in Cuba to improve the current electrical, telecom, satellite and TV, LAN and audio/visual system infrastructure for certain high impact sectors”. These are characterized in the letter by OFAC as “transactions related to the improvement of deficiencies in the network and telecom infrastructure, satellite and cable television infrastructure, and audio visual infrastructure…” OFAC response combines a number of general licenses to come to the conclusion that the proposed activities do not requires a specific license. See https://www.govinfo.gov/content/pkg/CFR-2017-title31-vol3/xml/CFR-2017-title31-vol3-part515.xml for the CACR as they appeared at the relevant time.

2) TELECOM GL AND “INFRASTRUCTURE” GL; SCOPE AND OVERLAP

a. 515.542(d)

OFAC cites 515.542(d), authorizing...