31 CFR § 515.572 - Provision of travel, carrier, other transportation-related, and remittance forwarding services.

Date issued: Sep. 11 2024

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TURBOFAC Commentary (830 words)

Notes:

* [On 9-11-24, OFAC published an Interim final rule (https://ofac.treasury.gov/media/933201/download?inline) with a request for comments with a revision to 515.572 slated to take effect 180 days after 9-11-24. Consistent with the OFAC Guidance on Extension of Statute of Limitations and proposed new 501.601, the revised 515.572 would read the same as the current version, but change the reporting requirement at (b)(1) from "at least five years" to at least 10 years".

1) As clarified in Guidance Regarding Travel Between the United States And Cuba (2016), the "Note" to 515.572 is designed to narrow the scope of the carrier services GL vis-a-vis the travel services GL, especially as it relates to travel by third-country persons.

The complicated relationship between this provision, TSRA, and services in connection with travel by persons whose underlying travel is...