Civil Enforcement Information - IXTLAN Corporation

Date issued: Dec. 01 2006

TURBOFAC Commentary (149 words)

Notes:

1) For further factual information see "Busted! Oliver Stone Fined For Cuba Visit" at: https://deadline.com/2006/12/busted-oliver-stone-fined-for-cuba-visit-2-901/. These activities were (and still are) considered outside the scope of the exemption for information and informational materials, even though distribution of any films made would have been exempt from the CACR.

2) With respect to the "dealing in services" characterization, at the time of the enforcement action OFAC considered virtually all non-authorized travel to Cuba to constitute dealing in "services" in which Cuba has an interest. "Services" are listed as a sort of "property" within the scope of 515.201, so the legal basis for the penalty is the usual broad prohibition on dealing in property in which Cuba has an interest.

3) Compare Red Bull North America, Inc (2014).

4) This activity is now seemingly generally authorized by 515.545(b)(2).