Comprehensive Guidelines for License Applications to Engage in Travel-Related Transactions Involving Cuba

Date issued: May. 10 2012

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TURBOFAC Commentary (354 words)

Notes:


1) The “Comprehensive Guidelines for License Applications to Engage in Travel-Related Transactions Involving Cuba” were initially issued in 2004 (see version at p. 53 et seq. of native PDF), and were substantially amended in 2012 (p. 1 et seq.) The guidelines remained on OFAC’s website up through the Sept. 2015 Obama-era overhaul of the travel portion of the CACR to include much broader travel-related GLs than had existed at any point since the initial imposition of the embargo in 1963. (See also Case No. CT-2013-305303-1, referring to the guidelines as late as 4/25/2014). 


The guidelines document is notable primarily for the dozens of “examples” of Cuba travel-related factual scenarios, where OFAC explains whether such scenarios would be generally licensed or within the scope of a specific licensing policy. The travel GLs and specific licensing policies, as they existed up through 2014,...