Case No. CU-2016-329116-5, LICENSE No. CU-2016-329116-5

Date issued: Apr. 30 2019

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TURBOFAC Commentary (1299 words)

Consolidated Comment on Case No. CU-2016-329116-5, LICENSE No. CU-2016-329116-5 for Consolidated Comment on Case No. CU-2016-329116-1, License No. CU-2016-329116-1 through 4 and Case No. CU-2016-329116-5, LICENSE No. CU-2016-329116-5

1) The issuance and scope of these licenses answer key questions as they relate to (i) the ability of persons subject to the jurisdiction of the United States (within the meaning of the CACR at 515.329) to offer travel-related services to persons not subject to the jurisdiction of the United States, and (ii) OFAC’s licensing policies concerning the same question.

As discussed at length in General Note on the Provision of Services Related to Travel by non-U.S. Persons to Cuba, the CACR are somewhat ambiguous as it relates to the question of whether and to what extent 515.572 and