Case No. CU-2019-359325-1 (11/21/2019)

Date issued: Nov. 21 2019

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (756 words)

Notes:

* For commentary on this guidance letter in the context of other Research System letters dealing with this topic, see General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).

1) The relationship between sanctioned person membership in U.S. person professional/sporting organizations and the “informational materials” exemption

Compare Case No. CU-2014-309068-1, CU- 2015-317611-1 (CACR; issued close in time and in which OFAC determines that U.S. persons may "provide membership services to WTC Havana" and collect dues under the exemption at 515.206 “[t]o the extent that [U.S. persons'] membership includes access to exempt information or other informational materials”. See also General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).

In this letter, OFAC says:

“With respect to admitting Cuban nationals...