I know the Grand Hotel Kempinski Manzana is on the restricted list for US Citizens.
However, I'm a bit confused about the provision below. Does this mean if I prepay a travel agency not on the list for a night's stay at the hotel rather than the hotel directly, I'm not in violation of OFAC's rule?

Section 515.421 of the CACR contains an interpretive provision for incidental transactions where OFAC has clarified that authorized transactions ordinarily incident to licensed transactions exclude direct financial transactions with such entities and subentities if the terms of the applicable general or specific license expressly exclude such direct financial transactions. For a complete description of the scope of the interpretive provision and the restrictions and exceptions that apply, see 31 CFR § 515.421. [09-06-2019]