ENF 51433 (Administrative Subpoena and Related Correspondence)

Date issued: Jul. 03 2018

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TURBOFAC Commentary (904 words)

Consolidated Comment on ENF 51433 (Administrative Subpoena and Related Correspondence) and ENF 51433 (Cautionary Letter).

1) BACKGROUND

The PDF file contains an administrative subpoena issued to Royal Caribbean in connection with cruises to Cuba, the response to the administrative subpoena, and a resulting cautionary letter. See Case No. CU-2015-320741-1 [Application Included] for more detail concerning the cruises, and the sources of authority therefor. Briefly, 515.572(a)(2) and 515.572(a)(4) authorized the provision of carrier services by vessel to Cuba, as well as lodging on the vessels, provided that the passengers qualified for one of the 12 categories of generally licensed travel contained in the CACR.

2) SCOPE OF ADMINISTRATIVE SUBPOENA; NEGOTIATIONS

As is typical of the administrative subpoenas on file, it is notable for the breadth of what is...