FAC No. CU-506321, License No. CU-084925a

Date issued: Nov. 12 2010

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TURBOFAC Commentary (729 words)

Notes:

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: