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Case No. CU-2016-329116-5
Expedia, Inc.
c/o Covington & Burling LLP
One City Center, 850 Tenth Street NW
Washington, DC 20001-4956
Attn: [ ]
Dear [ ]:
This responds to your request of April 16, 2019, (the "Application") to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), requesting authorization, on behalf of Expedia, Inc and its affiliates, (together, "Expedia"), to renew License No. CU-2016-329116-4, authorizing the provision of travel-related services, both online and offline, to persons who are not subject to U.S. jurisdiction and are traveling between a country other than the United States and Cuba, or within Cuba.
The Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR), administered by OFAC, prohibit all persons subject to the jurisdiction of the United States from dealing in property in which Cuba...
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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