License No. CT-2012-294798-1; Case No. CT-2012-294798-1

Date issued: Oct. 19 2012

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (241 words)

Notes:

1) Original PDF file contains itineraries and other related documents.

This cover letter and license were issued in connection with the group with which two well-known celebrities travelled to Cuba and were photographed engaging in tourist-like activities. This resulted in demands by certain Members of Congress for explanations from OFAC as to how this was permissible given the prohibitions of TSRA and the CACR (515.560(f)) against the licensing of "transactions in connection with tourist travel to Cuba."

See Letter from Treasury to Rep. Diaz-Balart re: SCP Cuba Travel (2013).

2) The "People to people" general license was significantly restricted in 2017, where the primary change was the addition of the requirement that "[t]he exchanges take place under the auspices of an organization that is a person subject...