OFAC has published 2 new FAQs, relating to information collection and recordkeeping requirements for providers of carrier or travel services to or from Cuba under US sanctions. They confirm that, in the case of customers travelling under a specific licence, carriers and travel service providers subject to US jurisdiction may retain the licence number on file in place of a physical or electronic copy of the licence itself. In addition, they caution that a certification from each customer, indicating the provision of the CACR authorising their travel, must be retained for at least 5 years from the date of the transaction, along with that customer’s name and address.
The updated list of FAQs is here.
Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...See profile for Michael O'Kane >