OFAC Enforcement - Hotelbeds USA, Inc.

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (790 words)

Notes:

1) NOTE COMMON TO THE THREE JUNE 13, 2019 CUBA-RELATED ENFORCEMENT ACTIONS

This enforcement action is one of three issued on the same day in connection with the provision of travel-related services in connection with travel to Cuba. Individual and Cubasphere, Inc. (2019), Expedia Group, Inc. (2019), and Hotelbeds USA, Inc. All three of these enforcement actions pertain to activities that took place between April 2011 and December 2014. Each individual enforcement is discussed separately, but it should be noted that, as a group, they serve to illustrate an important point about the risks of engaging in prohibited conduct with respect to which OFAC appears to decline enforcement action as a policy preference. The prohibited activity all took place during the Obama Administration, and ended just before the major relaxation of the embargo that began in January 2015. At that particular time,...

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Civil Enforcement Information - Hotelbeds USA, Inc.

TURBOFAC Commentary (790 words)