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CU-084925-a
FAC No. CU-506321 [NOV 12 2010]
ViajeHoy, LLC.
Mark A. Elias
8325 Coral Way
Miami, FL 33155
Dear Mr. Elias:
This is in reference to your application to November 3, 2010, of ViajeHoy LLC, to engage in travel transactions to Cuba. License CU-084925-a (the “license”), issued now by the Office of Foreign Assets Control (“OFAC”), pursuant to the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the (“CACR”) allows all transactions listed in 515.560(c) and such additional transactions that are directly incident to travel to, from, and within Cuba, for the purposes of providing the travel-related services authorized by 515.572 of the Regulations, subject to certain limitations (the “Employee Travel Authorization”). The License, which lists the authorized travelers (the “Authorized Travelers”), is enclosed.
By the terms of the License, OFAC in...
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1) The license and associated cover/guidance letter were issued at a time when the travel-related general licenses in the CACR were narrower than they are today (as of early 2022). See https://www.govinfo.gov/content/pkg/CFR-2010-title31-vol3/xml/CFR-2010-title31-vol3-part515.xml. 515.572 authorized, as it currently authorizes, the provision of carrier services to and from Cuba. There was (and is), however, no broad travel-related GL that allows providers of carrier services to travel to Cuba to conduct business related to the provision of such services (i.e. business incident to the provision of such services, not the actual provision of such services). This is why OFAC issued specific License No. CU-084925a.
At the time the guidance and license were issued 515.206 (Exempt transactions) contained the standard informational materials exemption, along with an “example” of exempt transactions that read as follows: