US Airlines & Cruise Ships Can Transport Foreign Passengers To Cuba; Can Starwood Accept Foreign Guests & Tourists? The Answer Is Yes.


The question: Did the Obama Administration authorize by regulation a United States company to earn revenues from an activity that is prohibited by law for United States persons?

If the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury authorized Stamford, Connecticut-based Starwood Hotels & Resorts Worldwide (2015 revenues exceeded US$5.7 billion) which is being acquired by Bethesda, Maryland-based Marriott International (2015 revenues exceeded US$14 billion) to accept payment from persons who are not within the twelve (12) categories of travelers defined by the OFAC, those persons could be defined as engaging in “tourist activities” within provisions of the Trade Sanctions Reform and Export Enhancement Act (TSREEA) of 2000, and thus be transactions prohibited by statute, not subject to regulatory interpretation.

If the OFAC authorized Starwood Hotels & Resorts Worldwide to earn revenues from “tourist activities,” United States-based airlines may have a means to dispute restrictions placed upon them by the OFAC and United States Department of Transportation (DOT).

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