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

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (345 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,...

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

TURBOFAC Commentary (345 words)