April 23, 2015: 8 OFAC removals from Burma sanctions

On April 23rd, OFAC delisted the following Burma sanctions program listings:

DAGON INTERNATIONAL LIMITED (a.k.a. DAGON INTERNATIONAL; a.k.a. DAGON INTERNATIONAL CONSTRUCTION COMPANY), Dagon Centre, 6th Floor, 262-264 Pyay Road, Myayingone, Sanchaung Township, Yangon, Burma [BURMA].
DAGON INTERNATIONAL (a.k.a. DAGON INTERNATIONAL CONSTRUCTION COMPANY; a.k.a. DAGON INTERNATIONAL LIMITED), Dagon Centre, 6th Floor, 262-264 Pyay Road, Myayingone, Sanchaung Township, Yangon, Burma [BURMA].
DAGON INTERNATIONAL CONSTRUCTION COMPANY (a.k.a. DAGON INTERNATIONAL; a.k.a. DAGON INTERNATIONAL LIMITED), Dagon Centre, 6th Floor, 262-264 Pyay Road, Myayingone, Sanchaung Township, Yangon, Burma [BURMA].
AUNG, Win (a.k.a. AUNG, Dagon Win; a.k.a. AUNG, U Win); DOB 1953; nationality Burma (individual) [BURMA] (Linked To: DAGON INTERNATIONAL LIMITED; Linked To: DAGON TIMBER LIMITED).
AUNG, U Win (a.k.a. AUNG, Dagon Win; a.k.a. AUNG, Win); DOB 1953; nationality Burma (individual) [BURMA] (Linked To: DAGON INTERNATIONAL LIMITED; Linked To: DAGON TIMBER LIMITED).
AUNG, Dagon Win (a.k.a. AUNG, U Win; a.k.a. AUNG, Win); DOB 1953; nationality Burma (individual) [BURMA] (Linked To: DAGON INTERNATIONAL LIMITED; Linked To: DAGON TIMBER LIMITED).
DAGON TIMBER LIMITED (a.k.a. DAGON TIMBER), Dagon Centre, 262-264 Pyay Road, Myaynigone, Yangon, Burma [BURMA].
DAGON TIMBER (a.k.a. DAGON TIMBER LIMITED), Dagon Centre, 262-264 Pyay Road, Myaynigone, Yangon, Burma [BURMA].

Link:

OFAC Notice

 

Notice to Exporters 2015/16: Changes to Schedules 1, 2, 3 of Export Control Order 2008

The Export Control Order has now been replaced by Export Control (Amendment) (No 2) Order 2015, as of April 17th. Notice to Exporters 2015/15 had given notice that, due to mistakes in firearms controls, this further set of changes would be necessary.

From the Notice, details of the changes to the 3 schedules of the Order:

4. A new national control (PL9010) covering firearms considered to be ‘Non Military ’ has been introduced in Schedule 3 (UK controlled dual-use goods, software and technology) to the Order (see Article 2(7) of the new amendment Order). Some new definitions related to the new firearms control have also been added.

5. This new control entry provides for a clearer alignment of the various controls on firearms found in the UK Military List (Schedule 2 to The Order) with that of the Common Military List of the EU (CFSP 2014/C 107/1). This will improve the implementation of Regulation (EU) No.258/2012. These changes do not introduce any new controls on firearms.

6. As a result of the creation of this new entry in Schedule 3, and items being re-aligned from Schedule 2, a number of consequential changes to Schedule 1 of the Order have been necessary (see Articles 2(2)-(4)). A new paragraph 10a has been added to ensure that trade controls continue to be applied to firearms in Schedule 3 PL9010 (see Article 2(5)).

7. This amendment Order has also allowed correction of small errors in some Schedule 2 control entries to ensure consistency with the EU Common Military List (see Article 2(6)). These amendments also include appropriate cross references to the control entries: ML1, ML2 and ML3 in Schedule 2 and the new PL9010 control in Schedule 3.

8. The UK Strategic Export Control Lists have been updated to reflect the above changes.

And on April 21st, the following note about non-military firearms was added to the item on PL9010:

*The term ‘Non Military Firearm’ simply means a firearm not covered by the Military List (Sch. 2). This is consistent with the definition of ‘Military’ in Article 2 of the Order. So any firearm described in the relevant control entries of the Military List (i.e. ML1 or ML2) or the associated Notes, should be viewed as ‘military’ and would therefore not be controlled by PL9010.

Links:

Notice to Exporters 2015/16

Export Control (Amendment) (No 2) Order 2015

Notice to Exporters 2015/15

UK Military List

Regulation (EU) No. 258/2012

UK Strategic Export Control Lists

 

OFAC Cuba Sanctions FAQ: Part III – Travel Services

28. Do air carriers need to obtain specific licenses from OFAC to provide services?

No. A new general license authorizes persons subject to U.S. jurisdiction to provide air carrierservices to, from, or within Cuba, in connection with authorized travel, without the need for aspecific license from OFAC. However, while no additional license is required from OFAC, aircarriers wishing to provide service will still need to secure regulatory approvals from otherconcerned U.S. Government agencies, including the Department of Transportation (Office of theSecretary and the Federal Aviation Administration) and the Department of Homeland Security.For a complete description of what the OFAC general license authorizes and the restrictions thatapply, please see 31 CFR § 515.572(a)(2).

29. Do travel service providers (such as travel agents and tour group operators) need to obtainspecific licenses from OFAC to provide services for travel to Cuba?

No. A new general license authorizes persons subject to U.S. jurisdiction, including travel agentsand tour group operators, to provide travel services in connection with authorized travel withoutthe need for specific licenses from OFAC. For a complete description of what this generallicense authorizes and the restrictions that apply, please see 31 CFR § 515.572(a)(1). Theprovision of services related to travel for tourist or other unauthorized travel to Cuba remainsprohibited.

20. Are airlines and travel service providers required to verify that an individual traveler isauthorized to travel to Cuba?

Persons subject to U.S. jurisdiction providing authorized carrier or travel services must retain forat least five years from the date of the transaction a certification from each customer indicatingthe provision of the CACR that authorizes the person to travel to Cuba. In the case of a customertraveling under a specific license, a copy of the license must be maintained on file. The namesand addresses of individual travelers must also be maintained on file for at least five years. See31 CFR § 515.572(b).

 

April 28, 2015: OFAC adds to terror rolls, removes a bunch of drug traffickers…

Yesterday, OFAC added the following 3 persons to the SDN List under its anti-terror sanctions:

ATRIS, Hussein (a.k.a. HUSSEIN, Atris); DOB 11 Nov 1964; POB Lebanon (individual) [SDGT].
FARAH, Meliad (a.k.a. “HUSSEIN”; a.k.a. “HUSSEIN, Hussein”); DOB 05 Nov 1980; citizen Australia; alt. citizen Lebanon (individual) [SDGT].
HASSAN, Hassan el-Hajj (a.k.a. HASSAN, Hassan El Hajj); DOB 22 Mar 1988; citizen Canada; alt. citizen Lebanon (individual) [SDGT].

and de-listed the following narcotics trafficking sanctions listings:

CASTANO GIL, Hector; DOB 24 Mar 1959; POB Amalfi, Antioquia, Colombia; Cedula No. 3371328 (Colombia) (individual) [SDNTK].
FONTES MORENO, Eleazar, c/o AGRICOLA GAXIOLA S.A. DE C.V., Hermosillo, Sonora, Mexico; c/o TEMPLE DEL PITIC S.A. DE C.V., Hermosillo, Sonora, Mexico; Avenida Serdan No. 122 Poniente, Altos 10, Hermosillo, Sonora, Mexico; Ave. Real 73, Hermosillo, Sonora 83200, Mexico; DOB 23 Jul 1947; POB Hermosillo, Sonora, Mexico; nationality Mexico; citizen Mexico; Passport 260057687 (Mexico); C.U.R.P. FOME470723HSRNRL05 (Mexico) (individual) [SDNTK].
CANAVAL LANDAZURI, Enrique Antonio, c/o VUELA PERU S.A.C., Lima, Peru; c/o ASOCIACION CIVIL LOS PROMOTORES AERONAUTICOS, Lima, Peru; Avenida Pedro Venturo 687, URB Higuereta, Lima, Peru; DOB 06 Jan 1953; LE Number 07790775 (Peru) (individual) [SDNTK].
HERNANDEZ SAN MARTIN, Ricardo Arturo, c/o AVIANDINA S.A.C., Lima, Peru; c/o PERU GLOBAL TOURS S.A.C., Lima, Peru; Calle Huancavelica 270, URB Santa Patricia, Lima, Peru; DOB 04 Jul 1955; LE Number 10321329 (Peru) (individual) [SDNTK].
GUBEREK GRIMBERG, Arieh, Bogota, Colombia; DOB 17 Sep 1959; POB Bogota, Colombia; Cedula No. 79149680 (Colombia) (individual) [SDNTK] (Linked To: SBT S.A.; Linked To: PROMESAS DEL FUTBOL COLOMBIANO S.A.; Linked To: COMERCIALIZADORA INTERNACIONAL ANDINA LIMITADA; Linked To: COLOMBO PERUANA DE TEJIDOS S.A.; Linked To: COMPANIA REAL DE PANAMA S.A.; Linked To: GUBEREK GRIMBERG E HIJOS Y CIA. S. EN C.).
CARTRONIC GROUP PERU S.A.C., Lima, Peru; RUC # 20544359160 (Peru) [SDNTK].
ANDRADE QUINTERO, Ancizar, c/o INMOBILIARIA BOLIVAR LTDA., Cali, Colombia; c/o INMOBILIARIA U.M.V. S.A., Cali, Colombia; c/o SERVICIOS INMOBILIARIAS LTDA., Cali, Colombia; DOB 23 Jan 1962; Cedula No. 16672464 (Colombia) (individual) [SDNT].
J. FREDDY MAFLA Y CIA. S.C.S., Carrera 4 No. 11-45 Ofc. 503, Cali, Colombia; NIT # 800020482-4 (Colombia) [SDNT].
MAFLA POLO, Jose Freddy, Carrera 4 No. 11-45 Ofc. 503, Cali, Colombia; Calle 52N No. 5B-111, Cali, Colombia; Carrera 11 No. 46-24 Apt. 201, Cali, Colombia; Carrera 11 No. 46-26, Cali, Colombia; c/o COMPANIA DE FOMENTO MERCANTIL S.A., Cali, Colombia; c/o PARQUE INDUSTRIAL PROGRESO S.A., Yumbo, Colombia; c/o CONSTRUCCIONES PROGRESO DEL PUERTO S.A., Puerto Tejada, Colombia; c/o GEOPLASTICOS S.A., Cali, Colombia; c/o J. FREDDY MAFLA Y CIA. S.C.S., Cali, Colombia; POB Cali, Valle, Colombia; Cedula No. 16689935 (Colombia); Passport 16689935 (Colombia) (individual) [SDNT].
MARIN ZAMORA, Jaime Alberto (a.k.a. “BETO MARIN”), c/o PLASTEC LTDA., Colombia; Carrera 13A No. 1A-139, Armenia, Quindio, Colombia; Avenida San Martin 4-46, Bocagrande, Cartagena, Colombia; DOB 22 Jul 1964; POB Quimbaya, Quindio, Colombia; citizen Colombia; Cedula No. 7544228 (Colombia); Passport AF595263 (Colombia); alt. Passport AD380146 (Colombia) (individual) [SDNT].
“BETO MARIN” (a.k.a. MARIN ZAMORA, Jaime Alberto), c/o PLASTEC LTDA., Colombia; Carrera 13A No. 1A-139, Armenia, Quindio, Colombia; Avenida San Martin 4-46, Bocagrande, Cartagena, Colombia; DOB 22 Jul 1964; POB Quimbaya, Quindio, Colombia; citizen Colombia; Cedula No. 7544228 (Colombia); Passport AF595263 (Colombia); alt. Passport AD380146 (Colombia) (individual) [SDNT].
PLASTEC LTDA., Km. 1 Via Jardines, Armenia, Quindio, Colombia; NIT # 801000358-7(Colombia) [SDNT].
GAVIRIA MOR Y CIA. LTDA., Calle 16 No. 11-82 Ofc. 302, Girardot, Colombia; NIT # 800212771-2 (Colombia) [SDNT].
MORENO FERNANDEZ, Monica, c/o RUIZ DE ALARCON 12 S.L., Madrid, Spain; Spain; DOB 20 Apr 1963; nationality Colombia; citizen Colombia; Cedula No. 31903968 (Colombia); Passport AG744728 (Colombia); alt. Passport AE613367 (Colombia); National Foreign ID Number X3881333Z (Spain) (individual) [SDNT].
ESPITIA PINILLA, Ricardo, Bogota, Colombia; DOB 26 Apr 1962; POB Colombia; nationality Colombia; citizen Colombia; Cedula No. 19483017 (Colombia); Passport AI264250 (Colombia) (individual) [SDNT].

and changed the listings for the following 2 individuals designated under the narcotics trafficking sanctions:

CALLE QUIROS, Luis Santiago, Madrid, Spain; Lima, Peru; DOB 22 Jul 1965; POB Madrid, Spain; citizen Spain; alt. citizen Peru; D.N.I. 01927713-Z (Spain); alt. D.N.I. 10831176-8 (Peru) (individual) [SDNTK] (Linked To: TEXTIMAX SPAIN S.L.; Linked To: CASTIZAL MADRILENA S.L.; Linked To: INMOBILIARIA CASTIZAL S.A.C.; Linked To: UCALSA PERU S.A.; Linked To: CARTRONIC GROUP PERU S.A.C.). -to- CALLE QUIROS, Luis Santiago, Madrid, Spain; Lima, Peru; DOB 22 Jul 1965; POB Madrid, Spain; citizen Spain; alt. citizen Peru; D.N.I. 01927713-Z (Spain); alt. D.N.I. 10831176-8 (Peru) (individual) [SDNTK] (|Linked To: TEXTIMAX SPAIN S.L.; Linked To: CASTIZAL MADRILENA S.L.; Linked To: INMOBILIARIA CASTIZAL S.A.C.; Linked To: UCALSA PERU S.A.|).
MALDONADO ESCOBAR, Fernando; DOB 16 May 1961; POB Bogota, Colombia; Cedula No. 19445721 (Colombia); Passport AH330349 (Colombia) (individual) [SDNT] (Linked To: AUDITORES ESPECIALIZADOS LTDA.; Linked To: GAVIRIA MOR Y CIA. LTDA.; Linked To: AQUAMARINA ISLAND INTERNATIONAL CORPORATION). -to- MALDONADO ESCOBAR, Fernando; DOB 16 May 1961; POB Bogota, Colombia; Cedula No. 19445721 (Colombia); Passport AH330349 (Colombia) (individual) [SDNT] (|Linked To: AUDITORES ESPECIALIZADOS LTDA.; Linked To: AQUAMARINA ISLAND INTERNATIONAL CORPORATION|).

Link:

OFAC Notice

 

April 21, 2015: 5 more people, 1 entity added to OFAC’s TCO sanctions

On April 21st, OFAC added the following 5 individuals:

DIRIYE, Ahmed (a.k.a. ABDIKARIM, Sheikh Mahad Omar; a.k.a. ABU UBAIDAH, Ahmad Umar; a.k.a. ABU UBAIDAH, Ahmed Omar; a.k.a. ABU UBAIDAH, Sheikh Ahmad Umar; a.k.a. ABU UBAIDAH, Sheikh Ahmed Umar; a.k.a. ABU UBAIDAHA, Sheikh Omar; a.k.a. DIRIYE, Mahad; a.k.a. UMAR, Sheikh Ahmed; a.k.a. “DIRIYE, Abu”; a.k.a. “UBAIDAH, Abu”; a.k.a. “UMAR, Ahmad”), Somalia; DOB 1972; POB Somalia (individual) [SDGT].

KARATE, Mahad (a.k.a. KARATE, Mahad Mohamed Ali; a.k.a. KARATE, Mahad Warsame Qalley; a.k.a. WARSAME, Abdirahim Mohamed); DOB 1957 to 1962; POB Xarardheere, Somalia (individual) [SDGT].

MAZIOTIS, Nikolaos (a.k.a. MAZIOTIS, Nikos); DOB 01 Oct 1971; POB Edessa, Pella, Greece; Identification Number P146821/1993 (individual) [SDGT].

TAKEUCHI, Teruaki (Japanese: 竹内照明), Midori-ku, Nagoya, Aichi, Japan (Japanese: 緑区, 名古屋市, 愛知県, Japan); DOB 01 Feb 1960 to 29 Feb 1960 (individual) [TCO] (Linked To: KODO-KAI; Linked To: YAMAGUCHI-GUMI; Linked To: TAKAYAMA, Kiyoshi).

XIROS, Christodoulos; DOB 1958; alt. DOB 1959; POB Ikaria, Greece (individual) [SDGT].

and one entity:

KODO-KAI (Japanese: 弘道会) (a.k.a. KODOKAI; a.k.a. KOUDOU-KAI; a.k.a. SANDAIME KODO-KAI (Japanese: 三代目弘道会); a.k.a. THIRD KODO-KAI), 1-117 Shukuatocho, Nakamura Ward, Nagoya, Aichi, Japan (Japanese: 1-117 宿跡町中村区, 名古屋市, 愛知県, Japan) [TCO] (Linked To: YAMAGUCHI-GUMI; Linked To: TAKAYAMA, Kiyoshi; Linked To: SHINODA, Kenichi).

to the SDN List under the Transnational Criminal Organizations (TCO) sanctions program.

Link:

OFAC Notice

 

April 16, 2015: Hang Seng latest victim of fraudulent email

Press Releases
Fraudulent email purporting to be related to Hang Seng Bank, Limited

The Hong Kong Monetary Authority (HKMA) wishes to alert members of the public to an e-mail purporting to be sent from Hang Seng Bank, Limited (HSB). The e-mail requests customers to use an embedded hyperlink to connect to a fraudulent website (for example, “http://www.sugra.com/hang/ssl-banking/en/index2.html”, “http://www.apptics.com/wp-content/hk/” and “http://www.svc.cat/dd/”) and provide their account information such as the Internet banking logon user name and password. HSB has clarified that it has not sent these e-mails to its customers and has no connection with the fraudulent website.

Anyone who has provided his or her personal information to the website, or has conducted any financial transactions through the website should contact HSB at 2822 0203 and any local police station or the Cyber Security and Technology Crime Bureau of the Hong Kong Police Force at 2860 5012.

“Members of the public are reminded not to access their Internet banking accounts through hyperlinks embedded in e-mails, Internet search engines or suspicious pop-up windows. Instead, they should access their Internet banking accounts by typing the website addresses at the address bar of the browser, or by bookmarking the genuine website and using that for access. In addition, banks are not expected to send e-mails asking their customers to provide their account information (e.g. Internet banking logon passwords) or verify their account information online. If in doubt, they should contact their banks,” said an HKMA spokesperson.

Hong Kong Monetary Authority

16 April 2015

Link:

HKMA Notice

 

OFAC’s Cuba Sanctions FAQ – Part II: Travel

5. What are the travel changes to the Cuba program?

OFAC has issued general licenses within the 12 categories of authorized travel for many travel-related transactions to, from, or within Cuba that previously required a specific license (i.e., anapplication and a case-by-case determination).

Travel-related transactions are permitted by general license for certain travel related to thefollowing activities, subject to criteria and conditions in each general license: family visits;official business of the U.S. government, foreign governments, and certain intergovernmentalorganizations; journalistic activity; professional research and professional meetings; educationalactivities; religious activities; public performances, clinics, workshops, athletic and othercompetitions, and exhibitions; support for the Cuban people; humanitarian projects; activities of private foundations or research or educational institutes; exportation, importation, or transmissionof information or information materials; and certain authorized export transactions.

6. Do travelers who fall within the scope of a general license need to submit a written requestto OFAC for permission to travel or conduct transactions?

No. No further permission from OFAC is required to engage in transactions by a person whomeets all criteria in a general license. Individuals wishing to engage in activities that may fallwithin the scope of a general license should review the relevant general licenses contained in theCACR to determine whether their travel-related transactions are covered by such general licenses.Persons subject to U.S. jurisdiction who wish to engage in any travel within the 12 categories ofactivities specified in the CACR that does not meet the requirements of a general license willneed to apply for a specific license from OFAC.

7. Is travel to Cuba for tourist activities permitted?

No. Consistent with the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA),travel-related transactions involving Cuba are only permitted for the 12 categories of activitiesidentified in the CACR. Travel-related transactions for other purposes remain prohibited.

8. What constitutes “a close relative” for generally authorized family travel

OFAC regulations generally authorize U.S. persons and those sharing a dwelling with them as afamily to visit a close relative in Cuba, including a close relative who is a Cuban national orordinarily resident there, who is a U.S. Government official on official government business, orwho is a student or faculty member engaging in authorized educational activities in Cuba with aduration of over 60 days. A close relative is defined as any individual related to a person byblood, marriage, or adoption who is no more than three generations removed from that person orfrom a common ancestor with that person.” For a complete description of what this generallicense authorizes and the restrictions that apply, please see 31 CFR § 515.339 and § 515.561.

9. Who is generally authorized to engage in travel and travel-related transactions for“journalistic activity”?

OFAC has issued an expanded general license that incorporates prior specific licensing policyand authorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to journalistic activities in Cuba. Among other things, this generallicense authorizes, subject to appropriate conditions, full-time journalists, supporting broadcast ortechnical personnel, and freelance journalists to travel to Cuba. The traveler’s schedule ofactivities must not include free time or recreation in excess of that consistent with a full-timeschedule. An entire group does not qualify for the general license merely because some membersof the group qualify individually. For a complete description of what this general licenseauthorizes and the restrictions that apply, please see 31 CFR § 515.563.

10. What constitutes generally authorized travel-related transactions for “professionalresearchand professional meetings” in Cuba?

OFAC has issued an expanded general license that incorporates prior specific licensing policyand authorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to professional research in Cuba. Among other things, this generallicense authorizes, subject to appropriate conditions, professional research in Cuba relating to a traveler’s profession, professional background, or area of expertise. The traveler’s schedule ofactivities must not include free time or recreation in excess of that consistent with a full-timeschedule. An entire group does not qualify for the general license merely because some membersof the group qualify individually. For a complete description of what this general licenseauthorizes and the restrictions that apply, please see 31 CFR § 515.564.

OFAC has issued an expanded general license that incorporates prior specific licensing policyand authorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to professional meetings in Cuba. Among other things, this generallicense authorizes, subject to appropriate conditions, professional meetings or conferences inCuba relating to a traveler’s profession, professional background, or area of expertise, providedthat the purpose of the meeting or conference is not the promotion of tourism in Cuba. Travel inthis category is generally licensed provided that the traveler’s schedule of activities does notinclude free time or recreation in excess of that consistent with a full-time schedule. An entiregroup does not qualify for the general license merely because some members of the group qualifyindividually. For a complete description of what this general license authorizes and therestrictions that apply, please see 31 CFR § 515.564

11. What constitutes “educational activities” for generally authorized travel

OFAC has issued an expanded general license that incorporates prior specific licensing policyand authorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to certain educational activities in Cuba. Among other things, thisgeneral license authorizes, subject to appropriate conditions, faculty, staff, and students at U.S.academic institutions and secondary schools to engage in certain educational activities in Cuba,Cuban scholars to engage in certain educational activities in the United States, certain activities tofacilitate licensed educational programs, and certain people-to-people travel. An entire groupdoes not qualify for the general license merely because some members of the group qualifyindividually. For a complete description of what this general license authorizes and therestrictions that apply, please see 31 CFR § 515.565.

12. Are secondary schools and secondary school students permitted to engage in travel-relatedtransactions under the general license for “educational activities”?

Yes. Educational exchanges sponsored by Cuban or U.S. secondary schools involving secondaryschool students’ participation in a formal course of study or in a structured educational programoffered by a secondary school or other academic institution, and led by a teacher or othersecondary school official, are authorized under this general license. For a complete description ofwhat this general license authorizes and the restrictions that apply, please see 31 CFR § 515.565(a)(6). This provision allows for participation of a reasonable number of adult chaperones toaccompany the secondary school student(s) to Cuba.

13. What constitutes “people-to-people travel” for generally authorized travel?

OFAC has issued a general license that incorporates prior specific licensing policy andauthorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to people-to-people educational activities in Cuba. Among other things,this general license authorizes, subject to appropriate conditions, persons subject to U.S.jurisdiction to engage in certain educational exchanges in Cuba under the auspices of anorganization that is a person subject to U.S. jurisdiction and sponsors such exchanges to promotepeople-to-people contact. Additionally, an employee, paid consultant, or agent of the sponsoring organization must accompany each group traveling to Cuba to ensure the full-time schedule ofeducational exchange activities, and the predominant portion of the activities must not be withindividuals or entities acting for or on behalf of a prohibited official of the Government of Cuba,as defined in 31 CFR § 515.337, or a prohibited member of the Cuban Communist Party, asdefined in 31 CFR § 515.338. For a complete description of what this general license authorizesand the restrictions that apply, please see 31 CFR § 515.565(b).

14. What is an “organization” in the people–to-people context?

In the people-to-people context, an organization is an entity subject to U.S. jurisdiction thatsponsors educational exchanges that do not involve academic study pursuant to a degree programand that promote people-to-people contact. For a complete description of what this generallicense authorizes and the restrictions that apply, please see 31 CFR § 515.565(b).

15. Who is generally authorized to engage in travel-related transactions for “religiousactivities”?

OFAC has issued an expanded general license that incorporates prior specific licensing policyand authorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to religious activities in Cuba. All persons subject to U.S. jurisdiction,including religious organizations located in the United States and members and staff of suchorganizations, are generally authorized to engage in travel-related transactions that are directlyincident to engaging in religious activities in Cuba provided, among other things, that the travelmust be for the purpose of engaging in a program of religious activities. The traveler’s scheduleof activities must not include free time or recreation in excess of that consistent with a full-timeschedule in Cuba. For a complete description of what this general license authorizes and therestrictions that apply, please see 31 CFR § 515.566.

16. What constitutes “public performances, clinics, workshops, athletic and other competitions,and exhibitions” for generally authorized travel?

OFAC has issued an expanded general license that incorporates prior specific licensing policyand authorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to participation in amateur and semi-professional international sportsfederation competitions as well as other athletic and other competitions and public performances,clinics, workshops, and exhibitions in Cuba. For a complete description of what this generallicense authorizes and the restrictions that apply, please see 31 CFR § 515.567.

17. What constitutes “support for the Cuban people” for generally authorized travel and othertransactions?

OFAC has issued a general license that incorporates prior specific licensing policy andauthorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are intended to provide support for the Cuban people, which include activities of recognizedhuman rights organizations; independent organizations designed to promote a rapid, peacefultransition to democracy; and individuals and non-governmental organizations that promoteindependent activity intended to strengthen civil society in Cuba. The traveler’s schedule ofactivities must not include free time or recreation in excess of that consistent with a full-timeschedule in Cuba. For a complete description of what this general license authorizes and therestrictions that apply, please see 31 CFR § 515.574.

18. What constitutes “humanitarian projects” for generally authorized travel and othertransactions?

OFAC has issued a general license that incorporates prior specific licensing policy andauthorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are related to humanitarian projects in or related to Cuba. These authorized humanitarianprojects include medical and health-related projects; construction projects intended to benefitlegitimately independent civil society groups; environmental projects; projects involving formalor non-formal educational training, within Cuba or off-island, on the following topics:entrepreneurship and business, civil education, journalism, advocacy and organizing, adultliteracy, or vocational skills; community-based grassroots projects; projects suitable to thedevelopment of small-scale private enterprise; projects that are related to agricultural and ruraldevelopment that promote independent activity; microfinancing projects, except for loans,extensions of credit, or other financing prohibited by 31 C.F.R. § 515.208; and projects to meetbasic human needs. The traveler’s schedule of activities must not include free time or recreationin excess of that consistent with a full-time schedule in Cuba. For a complete description of whatthis general license authorizes and the restrictions that apply, please see 31 CFR § 515.575.

19. What constitutes “activities of private foundations or research or educational institutes” forgenerally authorized travel?

OFAC has issued a general license that incorporates previous specific licensing policy andauthorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to activities by private foundations or research or educational instituteswith an established interest in international relations to collect information related to Cuba fornoncommercial purposes, among other things. The traveler’s schedule of activities must notinclude free time or recreation in excess of that consistent with a full-time schedule in Cuba. Fora complete description of what this general license authorizes and the restrictions that apply,please see 31 CFR § 515.576.

20. What constitutes exportation, importation or transmission of information or informationalmaterials” for generally authorized travel?

OFAC has issued a general license that incorporates prior specific licensing policy andauthorizes, subject to appropriate conditions, travel-related transactions and other transactionsthat are directly incident to the exportation, importation, or transmission of information orinformational materials in Cuba. The traveler’s schedule of activities must not include free timeor recreation in excess of that consistent with a full-time schedule in Cuba. For a completedescription of what this general license authorizes and the restrictions that apply, please see 31CFR § 515.545. The definition of “information and informational materials” may be found at 31CFR § 515.332.

21. Can I purchase a ticket to Cuba directly from an airline based or operating out of theUnited States?

Yes, provided that you are authorized to travel to Cuba pursuant to a general or specific license.Airlines subject to U.S. jurisdiction are authorized to provide air carrier services to authorizedtravelers, and travelers may purchase tickets provided that their travel is authorized pursuant tothe CACR. Airlines and travelers are responsible for maintaining records of their Cuba-relatedtransactions for at least five years.

22. May an individual authorized traveler use his or her private boat to travel to Cuba?

A person subject to U.S. jurisdiction engaging in authorized travel pursuant to an OFAC generalor specific license may use a personal boat for his or her travel, and the travel of the boat’s crew,to Cuba provided that he or she obtains a license from the Bureau of Industry and Security (BIS)for the temporary sojourn of the vessel. Goods exported to Cuba also require a license or must beeligible for a license exception from BIS.

23. Are U.S. vessels, including private boats and commercial passenger ferries, permitted tocarry passengers to Cuba?

The new general license allowing the provision of carrier services between the United States andCuba is limited to the provision of such services by aircraft; it does not authorize providingcarrier services by vessel. Providing carrier services by vessel would require a specific licensefrom OFAC. This would include an individual using his or her own personal boat to transportpassengers to Cuba. Vessels on temporary sojourn to Cuba also require a license from the Bureauof Industry and Security (BIS). Goods exported to Cuba also require a license or must be eligiblefor a license exception from BIS.

24. Are there any spending limits for authorized U.S. travelers while in Cuba?

The per diem rate previously imposed no longer applies, and there is no specific dollar limit onauthorized expenses. Authorized travelers may engage in transactions ordinarily incident totravel within Cuba, including payment of living expenses and the acquisition in Cuba of goods forpersonal consumption there; other expenditures, other than those directly incident to the traveler’sauthorized activities in Cuba, are not authorized. In addition, travelers are authorized to acquirein Cuba and import as accompanied baggage into the United States merchandise with a value notto exceed $400 per person, provided that no more than $100 of the merchandise consists ofalcohol or tobacco products and the merchandise is imported for personal use only.

25. Are there any restrictions on what foreign persons entering the United States from travelthat included Cuba may bring in their accompanied baggage?

A non-U.S. person (i.e. not a U.S. citizen or resident) arriving in the United States is authorized toimport Cuban-origin merchandise, other than tobacco and alcohol, as accompanied baggageprovided the merchandise is not in commercial quantities and not imported for resale. See 31CFR § 515.569. If the non-U.S. person is on a trip that included travel to Cuba, the person also isauthorized to import as accompanied baggage alcohol or tobacco products purchased or otherwiseacquired in Cuba with a value not to exceed $100 for personal use only. See 31 CFR §515.560(c)(3).

26. Can I purchase Cuban-origin cigars and/or Cuban-origin rum or other alcohol whiletraveling in Cuba?

Persons authorized to travel to Cuba may purchase alcohol and tobacco products while in Cubafor personal consumption while there. Authorized travelers may return to the United States withup to $100 worth of alcohol and/or tobacco products acquired in Cuba in accompanied baggage,for personal use only.

27. Can I purchase Cuban-origin cigars and/or Cuban-origin rum or other Cuban-originalcohol over the internet or while in a third country (i.e., not Cuba)?

No. These transactions remain prohibited, and OFAC has not issued any general license thatwould authorize them.