31 CFR § 515.420 - Travel to Cuba.

Date issued: Oct. 17 2016

TURBOFAC Commentary (135 words)

Notes:

Prior to 1994, 515.420 implemented a policy whereby OFAC considered it not to constitute a violation of 515.201(b) when, subject to certain conditions, "a person not subject to the jurisdiction of the United States covers the cost of all transactions related to the travel of the person subject to the jurisdiction of the United States (the "fully-hosted" traveler)." OFAC eventually changed its policy, and interpretation of 515.201, to consider that "even a person who accepts goods or services in Cuba without paying for them is in fact engaging in a prohibited dealing in property in which Cuba or a Cuban national has an interest."[1] This provision reflects that change in policy.

[1] https://www.govinfo.gov/content/pkg/FR-2004-06-16/pdf/04-13630.pdf#page=5