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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
Case No. CU-81874
Jose I. Valdes, Esq.
Law Offices of Eduardo Cosio, P.A.
1430 South Dixie Hwy., Suite 202
Coral Gables, FL 33146
Dear Mr. Valdes:
This responds to your letter dated August 8, 2011, and other correspondence, including a letter dated May 8, 2009, to the Department of the Treasury's Office of Foreign Assets Control ("OFAC"), regarding the transfer of funds to relatives and family members in Cuba from estates that are blocked pursuant to the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "Regulations"). As you know, the Regulations, administered by OFAC, prohibit all persons subject to the jurisdiction of the United States from dealing in property in which Cuba or a Cuban national has an interest unless authorized by a general or...
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1) For the CACR as they existed in 2011, see https://www.govinfo.gov/content/pkg/CFR-2011-title31-vol3/xml/CFR-2011-title31-vol3-part515.xml.
Of note is 515.570(f):
(f) Certain remittances from blocked sources authorized. Provided the recipient is not a prohibited official of the Government of Cuba, as defined in § 515.337 of this part, or a prohibited member of the Cuban Communist Party, as defined in § 515.338 of this part, certain remittances from blocked sources are authorized as follows:
(1) Funds deposited in a blocked account in a banking institution in the United States held in the name of, or in which the beneficial interest is held by, a national of Cuba as a result of a valid testamentary disposition, intestate succession, or payment from a life insurance policy or annuity contract triggered by the death of the policy or contract holder...