Letter from Treasury to Rep. Diaz-Balart re: SCP Cuba Travel (2013)

Date issued: Apr. 09 2013

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TURBOFAC Commentary (717 words)

Notes:

1) Letter issued in response to political outcry (in some quarters) over highly publicized trip to Cuba taken by two celebrities under the since-amended "people-to-people travel" general license for travel (515.565(b)).

2) Implicitly, OFAC/Treasury distinguishes between licenses "for tourist travel," which OFAC is prohibited from granting by TSRA (see 515.560(f)), and activities undertaken on "off hours" in the context of what is otherwise a "full-time schedule of educational exchange."

The implication appears to be that, provided that one's itinerary and completion of it is sufficient to meet the "full-time schedule" test, then other off-hour activities are permitted even if those activities are the sort that tourists might engage in.

3) The "People to people" general license was significantly restricted in 2017, where the primary change was the addition of the requirement that...