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July 24, 2006 

OFAC Claims Surgeon Violated Scope of Cuba Travel License

Scotland's The Herald newspaper reports that a Scottish trained maxillo-facial surgeon based in the U.S. has been advised by the Treasury Department's Office of Foreign Assets Control (OFAC) that he violated the terms of his humanitarian travel license during his last trip to Cuba. The article states that the surgeon and colleagues from the University of Minnesota had taken medicine to pass on to the Jewish community in Havana. However, upon his return to the U.S. OFAC advised the surgeon and his colleagues that they violated the terms of the OFAC travel license by engaging in unlicensed activities, such as meeting students and academics at Havana University and giving lectures.

While not indicated in the article, it appears that the surgeon was traveling under a "humanitarian projects" license issued by OFAC under 31 CFR 515.575 of the Cuban Assets Control Regulations. Such licenses permits license holders to engage in humanitarian projects in or related to Cuba designed to directly benefit the Cuban people. Persons traveling to Cuba under an OFAC license are not permitted to engage in activities that were not specified in their license applications.

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