Bonnie - Questions About Our Cruise to CUBA from Lisbon

Thank you Bonnie for the concise reply, it is genuinely appreciated.

I have since contacted OFAC yet again to ask about the impact of travelling on a “wholly owned US cruise line” from Lisbon, and from their answer below, I do now accept that this means every passenger on the Azamara Journey will be subject to US Jurisdiction.

I wish OFAC had read my enquiry properly in the first place, as I did state I was travelling on a wholly owned US cruiseline, but clearly they didn’t!

The answer I got today was : “If the entity providing the transportation to Cuba is a U.S. owned or run entity, all travelers they are transporting must be authorized, by general or specific OFAC license, to enter Cuba. Please review the Cuba FAQs #40-44 (https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf)”

But I do think this entire confusion and time-wasting could have been avoided if your Azamara Cuba FAQS were accurate in stating who is subject to US Jurisdiction and in particular why, instead of just stating on your Cuban FAQS that US Jurisdiction applies to passengers departing from a US Port... I hope Azamara will update their Cuban FAQs soon.

Thanks again.

Thank you Bonnie for the concise reply, it is genuinely appreciated.

 

 

I have since contacted OFAC yet again to ask about the impact of travelling on a “wholly owned US cruise line” from Lisbon, and from their answer below, I do now accept that this means every passenger on the Azamara Journey will be subject to US Jurisdiction.

 

I wish OFAC had read my enquiry properly in the first place, as I did state I was travelling on a wholly owned US cruiseline, but clearly they didn’t!

 

The answer I got today was : “If the entity providing the transportation to Cuba is a U.S. owned or run entity, all travelers they are transporting must be authorized, by general or specific OFAC license, to enter Cuba. Please review the Cuba FAQs #40-44 (https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf)”

But I do think this entire confusion and time-wasting could have been avoided if your Azamara Cuba FAQS were accurate in stating who is subject to US Jurisdiction and in particular why, instead of just stating on your Cuban FAQS that US Jurisdiction applies to passengers departing from a US Port... I hope Azamara will update their Cuban FAQs soon.

 

Thanks again.

A small clarification for accuracy. The received message from OFAC stated “If the entity providing the transportation to Cuba is a U.S. owned or run entity.......". To my knowledge the operable message here is "or run entity" as to my knowledge, none of the cruise lines based in the US are registered US companies. It is a bit complicated. Azamara is owned by Royal Caribbean Cruise Lines who is owned by Royal Caribbean Limited which is a Liberian Company. This after a Google Search. So, assuming my search was successful and moving the ownership to the registered company, think Azamara is technically a Liberian Company with headquarters and being run out of Miami so technically then it is the US run entity that requires on Azamara to follow OFAC and not the US owned option based on my hopefully correct search.

In any case it was good to get Bonnie's clarification as well as the information provided by Lobbylin from OFAC to put this issue to bed. It appears from the OFAC exert that the port of departure or arrival is not a determining factor