Civil Enforcement Information - Gate Gourmet, Inc

Date issued: Jul. 11 2008

TURBOFAC Commentary (204 words)

Notes:

1) This case contains a relatively straightforward example of "facilitation" under the CACR, even though there is no explicit prohibition against facilitation. While citing only the CACR generally, rather than a regulatory provision, OFAC leaves the precise provision violated a mystery. It has been suggested that the prohibition against facilitation in the CACR is found, dealing with 515.201(c), i.e. the evasion prohibition.

Without any facts suggesting deception, however, we look at somewhat analogous situations and presume that the basis for liability is 515.201(b). OFAC has described cases in which U.S. entities have facilitated travel to Cuba in 515.201(b)-like terms (e.g. Civil Enforcement Information - Travelocity, Inc. - "OFAC alleged that Travelocity provided travel-related services in which Cuba or Cuban nationals had an interest by arranging air travel and hotel reservations to, from, with or within Cuba without an OFAC license.")

In this case, the service (i.e. the referral) provided to a third-country person in connection with the Cuba business would constitute "property" in which Cubana airlines had an interest

Compare Great Western Malting Co. (2012), a similar Cuba facilitation case.

2) The direct provision of services to the Cuban entity and the sending of employees to Cuba are clear violations of 515.201.