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January 08, 2006 

OFAC to Reorganize Website / Updates FAQs

OFAC recently announced that it will engage in a "substantial reorganization " of the content on its website in the coming weeks. The announcement indicated that the "majority of . . . web content will be organized around the sanctions programs that OFAC administers." As a result, readers will be able to "find all material related to a specific sanctions program on a single page."

In addition, OFAC recently added the following item to the Frequently Asked Questions page on its website:

Question: Is a license required to enter into an overflight permit agreement with the Cuban Civil Air Authority, even if there is no cost?

Answer: Yes. A permit from the Government of Cuba is property in which the Government of Cuba has an interest. Therefore, a license from OFAC is necessary prior to obtaining the permit, even if no funds are changing hands at this point in the process. Many U.S. companies provide permitting and payment services on behalf of their clients. If such a facilitator holds an OFAC license to obtain the permits and make the payments to the Government of Cuba, there is no need for each individual client to obtain a separate OFAC authorization. [01-06-06].

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