31 CFR § 515.533 - Exportations from the United States to Cuba; reexportations to Cuba; importation and servicing or repair of certain items previously exported or reexported to Cuba.

Date issued: Sep. 24 2020

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TURBOFAC Commentary (4009 words)

Notes:

Comments Common to 515.559 and 515.533: Background to 515.559 and sections 1705 and 1706 of the CDA; Relationship with 515.533.

1) As mentioned in the "Note to paragraph (b)," 515.559 was (severely) restricted as a result of sections 1705 and 1706 of the Cuban Democracy Act of 1992. Prior to 1992, 515.559 articulated a statement of licensing policy allowing transactions between U.S.-owned or controlled firms in third countries and Cuba subject to the conditions in the current 515.559(b)(1), but not subject to the conditions in the current 515.559(a)(1)-(3). (See 515.559 Transactions by American-owned or controlled foreign firms with Cuba (1991, Cuba)).

Section 1706 of the CDA is framed as removing OFAC's authority (in terms of specific or general licenses) to license transactions that would have fit within the scope...