“22.11.88 OFAC [Office of Foreign Assets Control] amended its Cuban Assets Control Regulations by introducing further requirements and modifying existing restrictions applicable to persons rendering services related to traveling to Cuba or sending remittances to Cuban citizens on the island\u2026For the first time, it established the prohibition for persons traveling to Cuba to use credit cards to pay for their expenses incurred on the island\u2026These amendments include the elimination of general licenses issued to Cuba travel organizers, in favor of specific licenses valid for one year and subject to renewal\u2026It also required specific licenses, valid for one year and subject to renewal, for persons under U.S. jurisdiction, to provide services of collection and sending money remittances to close relatives in Cuba\u2026As for transactions of telephone and telegraph communications with Cuba, OFAC eliminated the established practice thus far of generally granting specific licenses, because the Department of the Treasury would review such requests on a case-by-case basis and in light of the policy being pursued by the Executive Branch at the moment the requests are filed. As for dealings with Cuba by U.S. subsidiaries abroad, OFAC struck down the provision that for these branches to be granted a license authorizing them to conduct business with Cuba, they had to have only a minority of American officers or directors. The specific licenses granted did not authorize any person in the United States to participate or be involved in licensed transactions with Cuba or Cuban nationals. Such compromise included the negotiation or execution of a transaction subject to license, but it was not limited to the assistance or participation of a U.S. company main office or any U.S. citizen or employee. Such participation could be the basis for the denial of a license request or for revoking a granted license. In order to obtain a license the partner should be generally independent in the handling of the transactions for whom the license is being sought, with regards to decision-making, risk-taking, negotiation, financing, and financing management and execution.\u201d [Pro Embargo]<\/p>\n