VZCZCXRO0337
PP RUEHAG RUEHDF RUEHHM RUEHIK RUEHJO RUEHLZ RUEHROV
DE RUEHLO #0764/01 0581716
ZNR UUUUU ZZH
P 271716Z FEB 07
FM AMEMBASSY LONDON
TO RUEATRS/DEPT OF TREASURY WASHDC PRIORITY
RUEHC/SECSTATE WASHDC PRIORITY 2046
INFO RUCNMEM/EU MEMBER STATES COLLECTIVE
RUEHXI/LABOR COLLECTIVE
RUEHNY/AMEMBASSY OSLO 0688
RUEHUB/USINT HAVANA 0020

UNCLAS SECTION 01 OF 02 LONDON 000764 
 
SIPDIS 
 
SIPDIS 
 
TREASURY FOR OFAC 
 
E.O. 12958: N/A 
TAGS: ETTC ELAB CU UK
SUBJECT: HILTON HOTELS CAUGHT BETWEEN US CUBA SANCTIONS AND 
UK NON-DISCRIMINATION LAW 
 
REF: LONDON 525 
 
LONDON 00000764  001.2 OF 002 
 
 
 
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LONDON 00000764  002 OF 002 
 
 
nationality.   Violations of both the US and UK laws are 
subject to severe civil and criminal penalties. 
 
The U.S. Sanctions, administered by the Office of Foreign 
Assts Control ("OFAC") at the U.S. Treasury Department, 
clearly prohibit US companies and their foreign subsidiaries 
from engaging in any transaction with Cuba, Cuban entities or 
Cuban nationals wherever located.   Aspects of these 
sanctions, particularly as to dealings with Cuban nationals, 
run counter to UK law. 
 
The United States has long been at the forefront of combating 
discrimination, including on the basis of national origin. 
Yet as a result of compliance with the US sanctions, Hilton 
is facing allegations of discriminatory practices against 
Cuban nationals on the basis of their national origin.  It is 
particularly difficult for a US based company such as Hilton 
to respond to such recriminations in light of the seeming 
inconsistency between the US anti-discrimination ethos as 
well as Hilton's own anti-discrimination policy, and the 
impacts of the sanctions as applied to Cuban national seeking 
lodging in our UK hotels. 
 
It is Hilton's policy to comply with all laws applicable to 
its operations.  This puts employees of Hilton in the UK in 
the extremely difficult situation of being left to choose 
between compliance with US Sanctions or UK law.  It also 
subjects Hilton to irreparable reputational harm if as a 
result of compliance with US Sanctions, Hilton is seen as a 
company that discriminates against travelers in violation of 
UK law. 
 
Hilton would like to see a reform of the US Sanctions within 
the tourism industry for US hotel companies (last three words 
in bold print) operating outside the United States so that 
this contradiction between US law and the laws of other 
countries, such as UK law, is eliminated.  To that end, we 
have submitted our own formal license application to OFAC for 
a specific license to authorize service to Cuban nationals. 
We are also working with the American Hotel and Lodging 
Association to make representations to the US State 
Department and Treasury to review these laws particularly 
with respect to their discriminatory effect based on 
nationality. 
 
(footnote 1: On 23rd March 2006 Hilton Group plc sold its 
hotel division, Hilton International, to the US based Hilton 
Hotels Corporation.  Hilton UK and Ireland currently operate 
73 hotels with over 14,000 rooms and 15,200 staff.) 
 
End text. 
 
¶7.   Embassy was contacted February 27 by The Guardian 
newspaper asking for comments on a statement it had received 
from Hilton on trade sanctions with Cuba.  The statement 
forwarded by the Guardian differs in some respects from the 
text in para 6.  One key difference is the following in the 
third paragraph of the statement: "However, notwithstanding 
this very serious dilemma, Hilton does not expect, require or 
counsel, its employees to violate their own country's laws. 
Accordingly, when dealing with bookings at our hotels in the 
UK, we do not expect or require that our UK employees do 
anything in violation of UK law." The Guardian statement also 
calls on the UK government to "make representations to the US 
and to bring a resolution to these issues."  The text of both 
documents has emailed to EUR/UBI and WHA/CCA desk, L/EB and 
L/WHA. 
 
Visit London's Classified Website: 
http://www.state.sgov.gov/p/eur/london/index. cfm 
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