Is there an OFAC exemption for "Mission Essentials"?

So it turns out that the Saddam's final days were not filled with wine, women, or song (at least, that story hasn't been printed yet). But they were apparently filled with some fruit that is currently forbidden to more than 300 Million Americans. According to this article, Saddam was provided Cuban Cigars while awaiting the hangman's noose in Bagdhad.

In September 2004, OFAC tightened, err, "clarified" the rules on purchasing Cuban Cigars in third countries. As a result, OFAC made it clear that not only can you not import your box of Cohibas into the United States, you can't even purchase and smoke them abroad without violating 31CFR§515.204 (or 410). For the last 3 years I have wondered why OFAC would feel the need to make such a clarification to rules that cannot possibly be enforced. I hadn't considered that it was targeted at US Military personnel providing stogies to deposed dictators.

The only applicable exemption I see in 515 is in section 562 but that only applies to US Government personnel actually travelling to, from, or in Cuba.

The military is deciding whether to court martial those involved; it will be interesting to see if OFAC decides to impose penalties on these individuals as well.