787. Are services related to caching, such as the provision of data storage systems that reduce internet network traffic, authorized by the CACR?

Yes. Section 515.578 authorizes the exportation or reexportation to Cuba of services incident to the exchange of communications over the internet. To the extent data caching services are incident to such exchanges of communications, the provision of such services is authorized. Section 515.578 also authorizes the exportation of services, including business consulting and information technology management services that are related to certain consumer communications devices. For instance, the provision by an internet or telecommunications provider of caching services related to items exported to Cuba pursuant to Commerce License Exception Consumer Communications Devices (CCD) or an individual license issued by Commerce is authorized. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.578.