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On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying…

On January 11, 2020, Secretary of State Michael Pompeo announced that the United States was re-designating Cuba as a State Sponsor of Terrorism for “repeatedly providing support for acts of international terrorism in granting safe harbor to terrorists.”  In a press release, the State Department noted that with this action, “we will once again hold…

On December 21, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three entities it has identified are controlled by the Cuban military and that have “strategic roles in the Cuban economy.” OFAC has placed the following three entities on the Specially Designated Nationals (SDN) List: (1) Grupo de Administración Empresarial…

On October 27, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register amending the Cuban Assets Control Regulations (CACR) to remove from the scope of generally authorized remittances any transactions involving “entities or subentities” identified on the U.S. Department of State’s Cuba Restricted…

On September 24, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Federal Register notice amending the Cuban Assets Control Regulations (CACR) in order “to further implement the President’s foreign policy to deny the Cuban regime sources of revenue.” The changes will restrict: (1) lodging at certain properties in Cuba;…

On April 16, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet noting that the sanctions programs it administers generally allow for legitimate humanitarian-related trade, assistance or activity under existing laws and regulations. The fact sheet provides consolidated guidance highlighting the most relevant exemptions, exceptions and authorizations for…

In his State of the Union address to Congress last night, President Donald Trump spoke of the “great American comeback” and claimed that “[t]he years of economic decay are over.  The days of our country being used, taken advantage of, and even scorned by other nations are long behind us.” His prepared speech focused briefly…

The Department of Commerce’s Bureau of Industry and Security (BIS) further tightened U.S. sanctions on Cuba “for its repression of the Cuban people and its support of the Maduro regime in Venezuela.” Overall, the United States maintains a comprehensive embargo on trade with Cuba, and the export and reexport to Cuba of items subject to…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that, effective October 9, 2019, the Cuban Assets Control Regulations (CACR) will be amended to further restrict certain financial transactions involving Cuba and to deny Cuba access to hard currency. In a press release, OFAC announced that these changes will amend certain…