31 CFR § 515.421 - Transactions ordinarily incident to a licensed transaction.

Date issued: Oct. 27 2020

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TURBOFAC Commentary (1754 words)

Notes:

1) Observe the varying status of Cubans that are i) SDNs, ii) On the CRL, iii) Are prohibited members of the Cuban Communist Party or iv) prohibited officials of the Government of Cuba.

It would appear that, to the degree transaction ancillary/ordinarily incident to an otherwise authorized transaction would need to involve a direct payment to a person identified on the Cuba Restricted List, this provision supersedes 515.209. Similarly, transactions with SDNs, whether listed or not, are permitted within the scope of this provision (compare all other analogous provisions). For persons identified as prohibited members of the Cuban Communist Party or prohibited officials of the Government of Cuba, it appears as though, provided that those parties are not excluded from the relevant GL, a transaction ordinarily incident to an authorized transaction may...