31 CFR § 515.208 - Restrictions on loans, credits and other financing.

Date issued: Jul. 18 1996

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TURBOFAC Commentary (1042 words)

Notes common to 515.208, 515.334, 515.335 and 515.336:

1) CACR sections 515.208, 515.334, 515.335 and 515.336, all initially issued on the same day [1], implement Sec. 103 of the Helms-Burton Act (officially, the "Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996")" [2]. None of the definitional provisions (515.334, 515.335 and 515.336) appear to have been the subject of formal guidance by OFAC. Refer to Note on Enforcement of Titles III and IV of the Helms-Burton Act (or "LIBERTAD Act") (System Ed. Note), for comments on the provisions of Helms-Burton Act that relate to dealings in certain "confiscated" property by persons not subject to the jurisdiction of the U.S.

2) The basic prohibition of 515.208, on which it appears no civil enforcement action has ever been based (at least not since 2006), is irregular when compared with...