Letter from OFAC to MLB re: Application of 515.571(e)

Date issued: Apr. 05 2019

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TURBOFAC Commentary (806 words)

Notes:

1) OFAC letter in re: an agreement between the MLB and the Cuban Baseball Federation whereby, in exchange for granting Cuban baseball players permission to emigrate to the U.S., the MLB pays the federation a sum of money.

The GL at issue provides, in relevant part, as follows:

§515.571 Certain transactions incident to travel to, from, and within the United States by Cuban nationals.

[...]
(e) The following transactions by or on behalf of a Cuban national are authorized:
(1) All transactions related to the sponsorship or hiring of a Cuban national to work in the United States in a non-immigrant status or pursuant to other non-immigrant travel authorization issued by the U.S. government, except that an employer may not make payments to the Cuban government in connection with the sponsorship or hiring of a Cuban...