31 CFR § 515.204 - Importation of and dealings in certain merchandise.

Date issued: Jul. 09 1963

Last substantive commentary amendment:
Nov. 11 2023

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TURBOFAC Commentary (1578 words)


1) This provision defines the scope of the CACR import ban, and ban on dealing in all goods of Cuban origin abroad.

Compare the combination of 560.201 and 560.206 of the ITSR. In one sense, the CACR version is broader insofar as dealings in products containing small amounts of Cuban origin materials are prohibited, even if they are first "substantially transformed" in a third country. On the other, the ban only applies to Cuban-origin products "outside the United States" on the effective date (compare 560.206, technically applying to 1000-year-old Persian antiques outside of Iran prior to the imposition of the embargo).

2) Typical import bans cover both "goods" and "services" (see e.g. 560.201). This provision only covers "merchandise," but "services" in which a Cuban...