Thursday, May 19, 2022

Statements on New US Policies


Fund for Reconciliation
and Development

Statement on New US Policies on Cuba

The Biden-Harrus Administration merits tremendous appreciation for new policies on Cuba  announced by the State Department on May 16, 2022.  They constitute a substantial albeit incomplete reconstruction of mutually beneficial engagement with Cuba.

The Administration has separated itself from the ideologically driven devastation of the Trump/Bolton /Claver-Carone era.  It is reinstating unrestricted family and donative remittances, people to people group travel, professional meetings and  research, regional flights, consular services, family reunification, emigration agreements and support for Cuban entrepreneurs.  These steps bring discernable benefit to the lives of the people of both countries.

Its action validates support by pro-engagement voters for Biden-Harris in the 2020 election and for similarly inclined candidates in the midterms of 2022.

We are gratified that virtually all of what was asked by over 5,000 petitioners mobilized by our organization is on the way to achievement and are encouraging everyone to express appreciation directly to the White House and/or through Congress to offset the tired complaints of old-guard Cuban Americans in Florida.   (Petition text and signers are here.)

Not surprisingly we regret President Biden and  Vice President Harris did not act sooner.  Significant movement at the beginning of their Administration could have avoided social turmoil last July, overreaction by Cuban security forces and disproportionate sentences of protesters. However, the Administration disproved skeptics who believed nothing significant would change until after the midterm elections, causing additional hardship and increasing the risk of more turmoil this summer. 

Reading the official summaries from the State Department leaves several questions in the air.  Additional steps are needed, but most importantly those already announced must be quickly and thoroughly implemented.   


1)  Will hotels become available again for use  by licensed travelers? 

Unless that happens group people to people tours and professional exchange programs will be impractical for most US travel agents, tour operators and sponsors.   Spreading a group of 10 or more visitors around several casas particulares or in the limited number of privately owned multi-room hostales is not feasible.

If the US returns to pre-Trump policies on use of State owned accommodations, the situation with Gaviota hotels needs to be thought through.  Gaviota's tragically lamented Saratoga was accessible to high end US visitors but the Kaminsky was not.  The new Aston is 49% owned by a major Indonesian company, Archipelago, and is so far not on the OFAC restricted list.  All of the boutique hotels in Old Havana that were created by Habaguanex, the company of the Historian's Office, are now held by GAESA.

2)  Will Cuba be allowed to trade dollars in the international market?  

Whether because of inclusion in the list of State Sponsors of Terrorism or the greater technological proficiency of sanctions implementation, Cuba can no longer trade USD internationally. Therefore it will not accept USD through any official channels, including CADECA  money exchanges, banks and State stores.  Prepaid MLC cards that are essential for many purchases are denominated in USD but must be bought with Euros, Canadian dollars, etc.

USD can be traded in the illegal market at a realistic exchange rate, over four times the official level, but that will make licensed US visitors uncomfortable and legally vulnerable.

3)  Will US banks be able to set up normal two-way correspondent accounts and undertake u-turntransactions with non-military Cuban banks?  

This has important implications for licensed group travel and for remittances.

4)  Will Americans again be able to legally bring home rum and cigars?

Travel includes being able to share  archetypical local products with family and friends.

5)  Can groups be self-organized by friends, colleagues and associations or can they only come under the auspices of both countries' commercial providers?  

This affects flexibility of program design and cost.  Most visitors in tour programs during the Obama era were older, white and financially comfortable. 

6)  Will cruises be permitted and Title 3 of Helms Burton be suspended again?  

Group people to people covers licensing, but additional permission for sailing is required from the Commerce Department.  Cruise companies need to be protected from destructive civil suits that dispute the legal authorization of their services.

7)  Are cultural and sports exchanges included?  

While they are clearly people to people, reciprocal exchanges require additional legal frameworks for contracts and support services.

8)  Why is individual  people to people independent travel not entitled to a general license?

Such discrimination is virtually impossible to enforce.  Support for the Cuban People in practice is effectively the same category and the distinction cannot be reasonably monitored.  In reality OFAC has not been willing or able to punish  individual travelers for license violations since its legal hearing system broke down during the Bush Administration.  Airlines can not be expected to distinguish whether a passenger is actually with a group or traveling independently but checking off the people to people box. 

Politically, the experience of independent American travelers is least shaped by agendas of Cuban officials.  Independent guides who work with independent travelers are asking the government for cuenta propista status.  The government has refused so far and forbidden micro, small and medium enterprise in the travel sector, in part for competitive reasons, in part to control messaging.  Independent guides nevertheless persist in finding clients.  The US government should not reinforce a State monopoly.  (I met with groups of independent guides in Varadero and Havana this month.  As a pro-engagement  pro-free market NGO, we enable their connection with American travelers who choose to be independent.)

One of the anonymous US official briefers correctly observed

facilitating group people-to-people travel will allow for greater engagement between the American people and the promotion of their democratic values.

But if US officials speak with independent travelers, they will discover that the democratic effect of  unfiltered unsupervised engagement by individuals is even stronger than for groups.  A small percentage will spend their time as tourists on the beach, but that doesn't mitigate the comparative advantage from the larger number of travelers who want to be independent just because of their serious interest in personal involvement with individual Cubans and their society.

Independent travelers are also the category that most assists the private sector of casas particulares and paladares for accommodations and meals, not to mention the revenue of Airbnb.

Ironically both governments are blocking the most rapid path to productive fruitful interaction and payment for services, independent individual and family travel by Americans residing in private homes whose visits are assisted by independent Cuban tour guides.   Group people to people programs organized by US tour operators and Cuban state receiving agencies will contribute substantially to economic recovery but require lead time and hotel access authorized by the US government.

9)  How much longer will remittances be delayed?

Right-wing opponents of US reopening are correct.  Barring association by US businesses with banks (and travelers with hotels) whose ultimate ownership is part of a military linked commercial holding company is a distinction without a difference.  In a State-centric economy, the door through which funds enter has only symbolic bearing on the door through which they are spent.  Pursuing cleaner appearing electronic banking channels when the efficient existing one received lower than prevailing service fees should not further impede desperately needed assistance from family and friends.  

10)  Can regional flights connect domestically to Havana?

This is ultimately the decision of Cuba, but it would greatly benefit Cuban-Americans and other US visitors if commercial flights from the US could make domestic connections.  For example a flight from Florida to Santiago (or Holguin or Camaguey) could go on to Havana before returning to Florida and vice-versa.  Until Cuba can lease or purchase equipment to amplify intercity services, this would open eastern Cuba for visits for all purposes that could be booked reliably from the US.

The reality that greater engagement can and should happen in a timely way does not diminish the vital humanitarian and political importance for the people of the US and Cuba of what the Biden-Harris Administration is now committed to doing.  

John McAuliff

May 19, 2022

(revised May 23, 2022)


  • Documents about the new policy from the State Department with highlighting can be read here.
  • Articles about the new policy with highlighting can be read here.


Two corrections of the Senior Administration Officials

The background anonymous briefing for the press on these policy changes referred to in published stories has been posted by the State Department and can be read here,  Two statements on related but extraneous topics should not stand unchallenged.

Whoever the "Senior Administration Official" is that said this needs to review the videos from the July 11-12 demonstrations:

"And the sentences that were imposed on people that were just singing in the streets and asking for food and to have a greater say in the future of their country really shows the situation ­ the lack of respect for human rights on the island."

Cuba's government overreacted to largely spontaneous protests and deserves criticism for repression and disproportionate sentences, but there are undeniable instances of theft from stores, violence, property destruction and rock throwing, retroactively justified by prominent supporters (reported here).   The cited words are like those from advocates of Black Lives Matter who deny what really happened because of identification with the righteousness of the cause.  Denialism also makes it harder to find a realistic diplomatic path to early release of prisoners.

I agree with the comment by a "Senior Administration Official" about the controversy over participation in June's Summit of the Americas 

"we should be focusing on addressing a whole host of shared challenges in the region and not blow up the summit over who shows up and who doesn’t"

However it is the US that has created this problem by introducing its own ideological criteria for attendance, seen as discredited hegemonism by other countries.

At the closing of the 2012 Summit in Cartagena, the host, Colombian President Juan Manuel Santos Calderon, declared:

El respeto y la tolerancia por las diferencias indican que somos una región madura con enorme potencial para realizar ambiciosos proyectos como los consignados en los mandatos de la VI Cumbre que tuvo como lema: “Conectando las Américas: Socios para la Prosperidad”.

La mayoría de países apoya la participación de Cuba en el Proceso de las Cumbres de las Américas e hicieron votos para hacer de este propósito una realidad a partir de la próxima Cumbre. 

[Respect and tolerance for differences indicate that we are a mature region with enormous potential to carry out ambitious projects such as those consigned in the mandates of the VI Summit which had as its motto: “Connecting the Americas: Partners for Prosperity”.

Most countries support Cuba's participation in the Summits of the Americas Process and they vowed to make this purpose a reality starting at the next Summit.]

The issue of universal participation will be as disruptive in the 19th Summit this June as it was in the 16th in 2012.  Only the US can prevent that from happening by showing respect for other nations' opinions.



Two steps forward, one back

Five days before the State Department took the positive steps described above, it lay the groundwork to reaffirm the grossly political Trump designation just before leaving office of Cuba as a State Sponsor of Terrorism.  It was published in the Federal Register on May 20th, four days after the breakthrough policy announcement.  In addition to being factually absurd and contrary to the findings of the Obama Administration, the designation erects many legal and financial obstacles for Cuba.  

Was someone trying to sabotage the opening roll out?  Was it done to appease (uselessly) Menendez, Rubio, et. al.?

DEPARTMENT OF STATE [Public Notice: 11747] Determination and Certification of Countries Not Cooperating Fully With Antiterrorism Efforts Pursuant to section 40A of the Arms Export Control Act (22 U.S.C. 2781), and E.O. 13637, as amended, I hereby determine and certify to the Congress that the following countries are not cooperating fully with United States antiterrorism efforts: Iran, Democratic People’s Republic of Korea (DPRK, or North Korea), Syria, Venezuela, and Cuba. This determination and certification shall be transmitted to the Congress and published in the Federal Register. Dated: May 11, 2022. Antony J. Blinken, Secretary of State. [FR Doc. 2022–10829 Filed 5–19–22; 8:45 am]


Center for Democracy in the Americas

CDA STATEMENT: CDA Applauds the Biden-Harris Administration's Move to Increase Engagement with Cuba

May 17, 2022

WASHINGTON - In response to the Biden-Harris administration’s May 16 announcement that it will reverse some sanctions on Cuba, the Center for Democracy in the Americas (CDA) released the following statement and policy recommendations:

“CDA applauds the Administration’s long-awaited decision to restore some areas of engagement with Cuba. Expanding flight authorization outside of Havana, restarting the Cuban Family Reunification Parole (CFRP) Program, and expanding support for entrepreneurs, educational travel, and remittances begins to fulfill the campaign promise of enacting a U.S. policy toward Cuba that supports the Cuban and Cuban American people. We encourage the Administration to continue expanding opportunities for Cuba’s growing private sector, providing pathways for Cubans to migrate under safe and orderly conditions, allowing Cuban American families to connect with their loved ones, and expanding pathways for humanitarian aid and dialogue around human rights. It is time to move beyond reversing policies put in-place by the previous Administration and towards a new approach or “third-way” that breaks from U.S. policy inertia, includes marginalized communities such as LGBTQI+ and Black Cubans, and enacts policies that go beyond merely supporting the Cuban people to being a true ally. 

Circumstances in both the US and Cuba warrant an approach that takes into account current migratory, economic, political, and global health realities. Increased travel and remittance avenues serve to support Cuba’s private sector, which, at the end of 2021, made up 13 percent of the country’s workforce. Cuba’s government also legalized and expanded permissible activities for small and medium size enterprises (SMEs), including allowing increased access to import and export services and wholesale markets. As experience demonstrates, increased U.S. travel to the island, U.S. engagement with Cuban entrepreneurs, and the facilitation of remittances generate success for Cuban and U.S. businesses alike. In addition to reauthorizing group people to people educational travel and flights to cities other than Havana, the Administration can further remove barriers to travel by reauthorizing individual people to people travel, and private and corporate aircraft travel. Beyond expanding U.S. travel, lifting sanctions that limit commercial and economic engagement, among other measures, could provide a sorely needed economic boost for Cuba’s private sector as the island faces an economic crisis.

It should be noted that these positive steps come just one month after the US and Cuba met to discuss the re-implementation of U.S.-Cuba migration accords; the Biden-Harris administration has demonstrated that it is willing to come to the table in the face of a migratory crisis. It also demonstrates that the Administration recognizes that the current influx of Cuban arrivals at U.S. borders will continue so long as the crisis in Cuba does, and so long as U.S. policy continues to isolate the island and serve as one of a myriad of push factors for Cuban emigration. To that end, a root cause strategy is required with Cuba, too, and the only way to implement such a strategy is through creative and active diplomacy. In addition, restarting the CFRP, which will begin to address a backlog of upwards of 110,000 visas, coupled with the Administration’s efforts to gradually shift visa services back to the U.S. Embassy in Havana, demonstrates a strong commitment to providing a streamlined and safe migration channel for Cubans. Legal pathways, with the support of a fully staffed U.S. Embassy in Havana, are the surest way to address the over 1,779 Cubans that have been interdicted at sea by the U.S. Coast Guard so far in Fiscal Year 2022 and the 22-year high in U.S. Customs and Border Patrol (CBP) apprehensions of Cubans along the U.S.-Mexico border. We cannot expect to make progress on issues that we differ on, such as human rights, if we’re not working on issues where we share interests, such as migration.

While the US works to support the Cuban people, it should not ignore Cuba’s government’s repressive actions through an isolationist policy. History has shown us that the best way to support human rights in Cuba and hold Cuba’s government accountable is through diplomacy and dialogue; for example, negotiations in 1978 resulted in the release of 3,000 Cuban political prisoners. Cuba’s new penal code, which was approved this week, implements harsher sentences, including the death penalty, for crimes against the security of the state, prohibits receiving financial support for conduct against the state, and increases, by ten-fold, the number of crimes punishable with life in prison. The concerning new measures follow the island-wide July 11 demonstrations in 2021, to which Cuba’s government responded with repressive actions, crackdowns, and widely criticized arrests, mass trials, and sentences of up to 30 years. Coming to the table and addressing policies of concern is the first step to laying the groundwork for change that truly benefits the Cuban people.

At a time when the US, Cuba, and countries of the region are facing increasing inequalities, racism, xenophobia, homophobia and transphobia, and economic and health crises, the time for creative and inclusive solutions is now. President Biden has the capacity to make palpable headway on U.S. policy goals and affect unprecedented progress by reimagining the US’s approach to Cuba through policies that deliver robust support for human rights and are built in partnership with marginalized communities and civil society. President Biden may have inherited the Trump administration’s Cuba policy, but he does not need to preserve it. As Cuba’s growing private sector and robust civil society seek a greater voice in the future of their country, President Biden has the opportunity to embark upon a new U.S.-Cuba policy that is not decided by history but informed by it.”


Washington Office on Latin America


The Biden Administration Takes Constructive First Steps on Cuba Relations

by Mariakarla Nodarse Venancio


On May 15, the Biden administration announced a series of measures that partially reverse former president Trump’s policies towards Cuba, taking long awaited steps that will enable it to pursue a more constructive approach regarding the Caribbean country. By recognizing the unprecedented humanitarian situation on the island, the administration has moved to increase support for the Cuban people while allowing Cuban-Americans to assist their families on the island. 

Although these measures mark the most significant changes in U.S. policy towards Cuba since President Biden took office, they are far cry from the Obama-era level of engagement. They should be seen as modest steps implemented in the context of a dramatic rise in the number of Cuban migrants apprehended at the U.S.-Mexico border, political pressure from other countries in the region pushing for Cuba to be invited to take part in the upcoming Summit of the Americas, and calls from members of Congress and other stakeholders for more U.S. engagement with Cuba. 

More than 78,000 Cubans have been apprehended in the U.S. border with Mexico since October, the highest number since the Mariel boatlift in 1980. Authorities in the Caribbean nation have also stopped accepting the return of their nationals despite a 2017 agreement. Recently, Mexico (Cuba accepts deportations from Mexico) has agreed to take back more Cuban migrants expelled by the U.S. under Title 42, but the majority of Cubans have been released on an immigration parole or under other supervision after expressing credible fear of prosecution.

Even though this spike in migration seems to have been one of the reasons behind the Biden administration resuming a dialogue with Cuba, the implementation of the U.S.-Cuba migration accords won’t be enough to stop the current influx of Cuban migrants. Most people fleeing the country are escaping an economic and humanitarian crisis that is exacerbated by U.S. isolationist policies. 

Under the new measures, the Biden administration will reinstate the Cuban Family Reunification Parole Program, which allows Cuban-Americans to apply for permission to bring family members to the United States as legal residents. It will also continue to increase capacity for consular services at the U.S. Embassy in Havana after immigrant visa processing slowly resumed on May 3, 2022. While this will benefit some Cuban-Americans and their families, staffing limitations at the embassy mean most people applying for immigrant and visitor visas will still have to travel to the U.S. Embassy in Georgetown, Guyana, which is the closest country in South America that does not require visas for Cubans. This represents an important barrier for many Cubans. Fully reinstating consular services in Havana could contribute to reducing irregular migration from Cuba to the U.S.

In another move that will primarily benefit Cuban-Americans seeking to visit relatives, the Biden administration will authorize flights from U.S. destinations to cities in Cuba other than Havana.   

It also seeks to facilitate authorized remittance flows by removing the current limit on family remittances of $1,000 per quarter per sender-receiver pair and authorizing donative (non-family) remittances. Allowing remittances to go to non-family members could expand their use for entrepreneurs and for humanitarian assistance. Although this is a positive move, sending remittances through FINCIMEX, the financial entity responsible for receiving these on the Cuban side, will remain prohibited since the military-owned company remains in the Cuba Restricted List. While the Biden administration stated it will engage with electronic payment processors to encourage increased Cuban market accessibility, there are no details yet about what channels Cuban-Americans and other U.S. citizens will be able to use to send remittances, and how convenient (or inconvenient) they will be. Western Union, the main provider of remittance payments from the U.S. to Cuba, closed its offices in the island in November 2020 after a number of Trump-imposed sanctions.

Lifting restrictions on remittances is also part of the Biden administration’s goal to support Cuban entrepreneurs. Other measures to encourage commercial opportunities outside of the state sector include easing independent Cuban entrepreneurs’ access to the Internet as well as to cloud technology, application programming interfaces, and e-commerce platforms. The administration will also expand support of additional payment options for Internet-based activities, support electronic payments, work to expand entrepreneurs’ access to microfinance and training, and facilitate business engagement. While these measures are, on paper, promising, the lack of specific guidelines on how they will be implemented means their full impact is difficult to assess at this time. 

Lastly, reinstating group people-to-people educational travel will facilitate connections for U.S. and Cuban citizens and generate jobs and income for the Cuban people. This is an important step in rebuilding dialogue and understanding, but the Cuba Prohibited Accommodations List (among other executive order-imposed restrictions) will continue to make travel plans for universities and other people-to-people groups extremely challenging. The impact of this announcement will depend on what regulations the Treasury Department establishes to manage group travel. Furthermore, if the goal is to support Cuba’s private sector, the travel expansion should include individual travel, since increased travel to the island can generate an economic boost, amidst the escalating economic crisis the island is facing.

Details are currently scarce on how these new policies will be implemented, and the Office of Foreign Assets Control (OFAC) within the Treasury Department will need to issue regulations to clarify the financial aspects of travel, remittances, and support for entrepreneurs.  

Nevertheless, these moves will undoubtedly have a positive impact on the Cuban economy and the daily lives of Cuban families. 

The administration must now work to implement these changes promptly and in ways that most benefit both the U.S. and the Cuban people, and to move forward with a policy of engagement that includes measures such as: 

The reinstatement of all forms of travel, both group and individual. The re-establishment of educational people-to-people travel notably excludes cultural and sport exchanges and is centered solely on academic and research purposes, creating further limitations on who gains access to the island. 

Ensuring the U.S. Embassy in Havana has full-fledged consular services and staff and that it no longer exports its responsibilities to its embassy in Guyana. It should also reinstate multiple entry visas (viable for up to 5 years) as an incentive for Cubans to remain on the island since they would have the ability to come and go via regular channels without having to choose to migrate completely. This is also an important method to alleviate the workload for an already understaffed embassy since it would lengthen the period of time between visa applications for Cubans. 

Revise and remove restrictions on U.S. banks to support the Cuban private sector in a more meaningful way—U.S. banks should have the ability to establish corresponding accounts with Cuban banks not managed by the military in order ease access to remittances and maximize their impact, especially for Cuban entrepreneurs. 

Resume conversations around the Memorandums of Understanding signed under the Obama administration. There are a number of high priority issues of common interest to the U.S. and Cuba, including security cooperation and environmental protection efforts among others. This channel for dialogue will also be key in addressing other concerns and making progress on critical issues such as the human rights situation on the island. Following the events of the 2021 protests, the mass trials that ensued, and the future implications of a new penal code in Cuba, the U.S. should prioritize a space to address these human rights concerns in the best interest of the Cuban people. 

Remove Cuba from the State Sponsor of Terrorism List which continues to complicate all major aspects of engagement with the island. \



By ACERE – Posted on May 17, 2022

On May 16, 2022, the Biden administration announced new measures towards Cuba, taking an important step towards restoring the policies of engagement and reversing some Trump-era policies.  ACERE welcomes the White House announcement, including the reinstatement of the Cuban Family Reunification Parole Program that will provide for the reunification of many Cuban families, as well as the promised increase of services and visa processing at the U.S. Consulate in Havana.  However, we are disappointed to learn that many visa applicants will continue to have to travel to Guyana for processing there.  Partly reinstating visa application procedures and recommitting to the minimum limits established by the U.S.-Cuba Migration Accords will help contribute to safer migration.  

Lifting the cap on family remittances and authorizing donative remittances is a long overdue announcement and will alleviate some of the suffering of ordinary Cuban citizens.  It is still unclear, however, how this will be carried out in practice given that Fincimex – the Cuban entity through which remittances are distributed in Cuba – remains on the U.S. sanctions list.  

Lastly, the U.S. will authorize access to certain digital services, including some applications, e-commerce platforms and electronic payment sites, in addition to granting entrepreneurs access to microfinancing.  To the extent that companies under U.S. jurisdiction will no longer face sanctions for offering their services in Cuba, those needing such services will have more opportunity to access them openly. 

ACERE welcomes these needed and overdue changes in U.S. policy towards Cuba.  They are a refreshing sign of a return to diplomacy and engagement, particularly after the recent high-level bilateral talks regarding the U.S.-Cuba Migration Accords. However, much remains to be done not only to restore U.S. policy to that of the Obama-Biden administration, but to move towards full normalization of relations. While these are significant steps forward, the reality is that over 200 cruel sanctions left by the Trump administration remain. 

Despite the easing of regulations, any travel to the island by people living in the U.S. must still be authorized by the Department of Treasury. The right to travel freely requires lifting all travel restrictions on U.S. citizens and residents’ ability to travel, including as tourists, and to engage in normal tourist activities without fear of facing sanctions. The Biden administration can and should reinstate the ability of U.S. citizens and residents to travel for educational “people to people” visits and to exchange ideas and experiences with people in Cuba. Cruise ships should not face fear of lawsuits or sanctions when offering to take people to Cuba, nor be responsible for restricting their travel itinerary based on what the U.S. government allows or disallows in another country’s sovereign space.  Reinstatement of the waiver under Title III of the Helms-Burton Act is an immediate and necessary step to show the travel sector that these new policy measures are substantive and not in name only.  

In addition, U.S. citizens and residents who travel to Cuba should be able to engage in normal financial transactions as they do everywhere else in the world, including using their credit cards.  Such transactions have been prohibited in Cuba, and made even more challenging by the totally unjustified U.S. placement of Cuba on the State Sponsors of Terrorism List, which deters most financial institutions from engaging in any sort of transaction with Cuba and limits Cuba’s ability to access credit for basic goods and services. Until Cuba is removed from the SSOT list, engaging in trade or receiving humanitarian assistance will be severely hampered, including as Cuba continues to respond to the COVID-19 pandemic and engage in global vaccine assistance efforts. 

While ACERE is encouraged by these initial small steps, the U.S. continues to spend more than $25 million per year in regime change programs against Cuba. Just as it is illegal for a foreign power to funnel millions of dollars to the United States in an effort to topple the government, it is a violation of international law for the United States to engage in similarly subversive activities against a neighboring country. 

Ultimately, ACERE urges the United States to lift the illegal embargo, which is still in place and has been condemned by nearly every member state of the United Nations. The embargo’s overt purpose is to strangle the Cuban economy to promote regime change.  We hope that as the Biden administration continues to undergo a review of its Cuba policy, lifting the embargo – which the President has the discretion to dismantle – will be the priority.


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