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1177. What internet-based services can be exported or reexported from the United States or by persons subject to U.S. jurisdiction to prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party?
Section 515.578(a)(4)(i) of the CACR authorizes the exportation or reexportation, directly or indirectly, from the United States or by a person subject to U.S. jurisdiction, to a prohibited official of the Government of Cuba, as defined in 31 CFR § 515.337, a prohibited member of the Cuban Communist Party, as defined in 31 CFR § 515.338, of certain internet-based services and services related to certain exportations and reexportations, as described in 31 CFR § 515.578(a)(1) or 31 CFR § 515.578(a)(2), respectively, provided that such services are widely available to the public at no cost to the user....
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1) This FAQ does not provide much in the way of substantive guidance. What is conveyed here is clear from the text of the GL.
* For comments on the scope of “communications”-related GLs in general, see section 5 of General Note on Prohibitions, Licenses and Exemptions as Applied to Social Media and Other Communications-Related Internet Services and Software (System Ed. Note).