PRINT
LICENSE No. CU-2018-354788-1
CUBAN ASSETS CONTROL REGULATIONS
LICENSE
(Issued under the authority of one or more of 50 U.S.C. § 4305(b), 22 U.S.C. § 2370(a) 22 U.S.C. §§ 6001 et seq., Proclamation 3447, and 31 C.F.R. Parts 501 and 515.)
To: Royal Caribbean Cruises Ltd.
WilmerHale
1875 Pennsylvania Ave. NW Washington, DC 20006
Attn: Ronald Meltzer, Esq.
1. Based upon the request dated July 6, 2018 as supplemented on July 24, 2018 and July 26, 2018, to the Office of Foreign Assets Control (the "Application") the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of the authorities cited above....
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) This specific license and associated application illustrate two important aspects of OFAC's licensing practices that are not otherwise discernible from the regulations.
First, the applicant asks for what is, in a sense, a sort of "wind down" license. OFAC allows a non-U.S. person that would have become subject to the CACR 515.329(d) as a result of being acquired by a U.S. person to complete certain activities post-acquisition that would have otherwise been prohibited. Note that the application was made prior to the closing of the acquisition transaction, but the license was granted soon after the acquisition transaction closed. It is not clear whether OFAC would have been willing to grant the license contingent on the deal closing and Silver Cloud becoming a U.S. person.
Second, § 7209 TSRA of provides as follows:
§...