On February 17, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a notice in the Federal Register seeking public comments on the effectiveness of the licensing procedures for the export and reexport of agricultural commodities to Cuba under the Export Administration Regulations (EAR). Specifically, the notice indicates that pursuant to section 906(a) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), BIS authorizes such exports and reexports and the procedures are set forth under 15 C.F.R. § 740.18. Persons submitting comments are asked to be as specific as possible.

Comments must be received by BIS no later than March 20, 2023, and must be submitted via the Federal rulemaking portal, www.regulations.gov, under docket no. BIS-2023-0004. BIS will include a description of any comments it receives in its biennial report to the Congress, as required by the TSRA. 

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.