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[liberationtech] Telecommunications to Cuba in New Policies

Collin Anderson collin at averysmallbird.com
Tue Aug 18 11:07:46 PDT 2015


Apple at least recognizes that these License Exceptions apply to their
equipment (they are quiet but decent when it comes to sanctions issues):
https://www.apple.com/legal/more-resources/gtc.html

License Except SCP is probably the shortest route to a permissible export
through perhaps the "private entrepreneurship" angle. I would call the BIS
hotline and see what they say.

On Tue, Aug 18, 2015 at 1:52 PM, Andrés Leopoldo Pacheco Sanfuentes <
alps6085 at gmail.com> wrote:

> Thanks, Collin!
>
> I was starting to look at those things yesterday, but wanted to see if
> there was a "shortcut" that would save me from having to sift through
> bureaucratic red tape doc piles.. :-)
>
> The situation is that of a Cuban Maestro in the US for a concert, wanting
> to purchase this type of equipment and stuff for his studio back home,
> including Apple gear but possibly also special-purpose hw & sw. Not a
> "commercial export.."
>
>
> Best Regards | Cordiales Saludos | Grato,
>
> Andrés L. Pacheco Sanfuentes
> <alps at acm.org>
> +1 (347) 766-5008
>
> On Tue, Aug 18, 2015 at 12:39 PM, Collin Anderson <
> collin at averysmallbird.com> wrote:
>
>> I cannot be your lawyer, but you might find some assurances within
>> License Exceptions Consumer Communications Devices (CCD)
>> <http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=9ae4a21068f2bd41d4a5aee843b63ef1&rgn=div5&view=text&node=15:2.1.3.4.25&idno=15#se15.2.740_119>
>>  and Support for the Cuban People (SCP) (§740.21 (d))
>> <http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=9ae4a21068f2bd41d4a5aee843b63ef1&rgn=div5&view=text&node=15:2.1.3.4.25&idno=15#se15.2.740_121> on
>> media production equipment.
>>
>> On Tue, Aug 18, 2015 at 3:21 AM, Andrés Pacheco <alps6085 at gmail.com>
>> wrote:
>>
>>>
>>> Quick, somewhat urgent question: where do sound studio / video equipment
>>> & software stand? Can they be exported to Cuba now?
>>>
>>> On Jan 15, 2015, at 10:01 AM, Collin Anderson <collin at averysmallbird.com>
>>> wrote:
>>>
>>> Hello Libtech,
>>>
>>> The Cuba new rules are out, since there are two jurisdictions covering
>>> the country, they are split between services (Treasury's OFAC) and goods
>>> (Commerce's BIS). The short story is that Cuba is close to Iran's policies
>>> now, which a bit of difference owing to how it was done. Positive news
>>> though.
>>>
>>> OFAC:
>>> https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-00632.pdf
>>> BIS:
>>> https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-00590.pdf
>>>
>>> Cordially,
>>> Collin
>>>
>>> On Thu, Jan 8, 2015 at 11:37 AM, Andrés Leopoldo Pacheco Sanfuentes <
>>> alps6085 at gmail.com> wrote:
>>>
>>>> I agree that the credit card stuff is by far the most important, and
>>>> not principally because of its implications in terms of "tech"
>>>>
>>>> Not sure about the impact or not of the "democracy promotion" programs,
>>>> but my feeling is that there's going to be a "surge" of those "programs!"
>>>> So what? I'm pretty sure though that hardly anybody in Cuba would stop
>>>> making a CC transaction in the island thanks to his US relatives & Obama
>>>> because of that..
>>>>
>>>>
>>>> Best Regards | Cordiales Saludos | Grato,
>>>>
>>>> Andrés L. Pacheco Sanfuentes
>>>> <alps at acm.org>
>>>> +1 (347) 766-5008
>>>>
>>>> On Wed, Dec 17, 2014 at 7:47 PM, Collin Anderson <
>>>> collin at averysmallbird.com> wrote:
>>>>
>>>>>
>>>>> On Wed, Dec 17, 2014 at 8:33 PM, Ellery Biddle <
>>>>> ellery.biddle at gmail.com> wrote:
>>>>>>
>>>>>> The financial piece here is also really important to follow, I think.
>>>>>> Although a lot of what Obama laid out today was actually somewhat
>>>>>> preliminary and short on detail, he very explicitly stated that US credit
>>>>>> cards would now be accepted in Cuba.
>>>>>
>>>>>
>>>>> Actually in this regard, perhaps the most important contribution will
>>>>> be the removal of Cuba from the state sponsors of terrorism list and the
>>>>> allowance of direct correspondent banking relationships.
>>>>>
>>>>> --
>>>>> *Collin David Anderson*
>>>>> averysmallbird.com | @cda | Washington, D.C.
>>>>>
>>>>> --
>>>>> Liberationtech is public & archives are searchable on Google.
>>>>> Violations of list guidelines will get you moderated:
>>>>> https://mailman.stanford.edu/mailman/listinfo/liberationtech.
>>>>> Unsubscribe, change to digest, or change password by emailing moderator at
>>>>> companys at stanford.edu.
>>>>>
>>>>
>>>>
>>>> --
>>>> Liberationtech is public & archives are searchable on Google.
>>>> Violations of list guidelines will get you moderated:
>>>> https://mailman.stanford.edu/mailman/listinfo/liberationtech.
>>>> Unsubscribe, change to digest, or change password by emailing moderator at
>>>> companys at stanford.edu.
>>>>
>>>
>>>
>>>
>>> --
>>> *Collin David Anderson*
>>> averysmallbird.com | @cda | Washington, D.C.
>>>
>>>
>>
>>
>> --
>> *Collin David Anderson*
>> averysmallbird.com | @cda | Washington, D.C.
>>
>
>


-- 
*Collin David Anderson*
averysmallbird.com | @cda | Washington, D.C.
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