A ‘Modest Proposal’ for Cuba: OFAC, BIS and State Department Implement President’s New Cuba Policy

November 24, 2017
By: EdKraul and, Brian Egan, Keith Huffman, Meredith Rathbone, Jack Hayes, Anthony Rapa, and Peter Jeydel*

Effective November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR), respectively, to implement changes to US Cuba sanctions policy articulated by President Trump in a presidential memorandum issued June 16, 2017. Concurrently, as required by the presidential memorandum, the Department of State published a list of 180 entities and sub entities associated with Cuban military, intelligence, and security services (Cuba Restricted List).  (more…)

Trump Sanctions Policies Still Undefined, But Could Affect Many Nations and Compliance Officers – Part 3: Steven Bannon’s “America First” Agenda Looms As Big Factor

January 31, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

In this series, we present the comments and assertions made by President Donald Trump and his top assistants concerning economic sanctions and export controls so compliance professionals can make informed decisions as to the likely positions of the new U.S.administration in the next four years. (more…)

What to Expect for Economic Sanctions Under President Trump?

January 13, 2017
By Anthony Rapa, Alexis Early and Peter Jeydel*

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he would terminate the Iran nuclear deal, and with it the sanctions rollback that has taken place over the past year, although actually convincing the rest of the world to re-impose sanctions on Iran would be a monumental feat of diplomacy.  On Cuba, Mr. Trump has given reasonably clear signals both that he would support the recent easing of sanctions and that he would reverse it, so the actual policy of the incoming Administration is hardly better than a 50/50 guess at this stage, though with the odds slightly favoring some tightening of sanctions.  Russia may be different.  That is one area in which Mr. Trump’s statements and actions point to a real possibility of a wholesale change in U.S. policy, although bipartisan congressional concerns with Russia may present a major obstacle to radically changing the current state of affairs, at least without significant concessions by Russia. (more…)

Cuba sanctions eased, but enforcement trend well behind the curve

December 14, 2016
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

On November 28, 2016, the first normally scheduled commercial flight landed in Havana from Miami on an American Airlines jet. The flight took place exactly 13 years 5 months and 1 day after the airline settled a US$47,250 enforcement action with US Treasury’s Office of Foreign Assets Control (OFAC) in 2003 for sanctions violations involving travel-related services to Cuba. (more…)

The U.S. Continues to Remove Restrictions on Cuba

Author: Michelle Roberts and Bruce Zagaris*
Date: June 6, 2016

In January, March and April 2016, the Obama Administration has continued to normalize relations with Cuba and reduce its unilateral sanctions. The latest regulations came just before an historic visit by President Obama to Cuba on March 21-22, 2016. This was the first such trip by a U.S. president in 88 years. The revisions since last September’s regulatory changes have related primarily to travel related transactions, especially those that will help the Cuban people and enhance people-to-people exchanges. The changes are discussed chronologically by month in which the changes occurred1. While general tourist travel is still not permitted, U.S. persons can easily travel to Cuba if their travel involves any of a number of favored categories. The U.S. has made significant changes to the restrictions on trade financing and a broadening of some of the prior authorizations described in our white paper of December 17, 2015. (more…)