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

April 26, 2017Agreement air authority Civil Cuban enter flight license permit

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

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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.