On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro
Reversing the Biden Administration, State Department Recreates the Cuba Restricted List
On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are
OFAC Updates Cuban Regulations to Increase Support for Cuban People
On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revised the Cuban Assets Control Regulations (CACR) to enhance support for the Cuban people and independent Cuban private sector entrepreneurs. These amendments, effective on May 28, 2024, aim to promote internet freedom and broaden financial services in Cuba. In
BIS Seeks Comments on Effectiveness of Licensing Procedures for Export of Agricultural Commodities to Cuba
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
OFAC and BIS Issue “Fact Sheet: Supporting the Cuban People’s Right to Seek, Receive, and Impart Information through Safe and Secure Access to the Internet”
On August 11, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet noting existing exemptions and authorizations available for companies, individuals and exporters to provide telecommunications-related goods and services to Cuba. The fact sheet lists OFAC general licenses
OFAC Sanctions Cuban Officials and Entities for Repression of Protestors
On July 22 and again on July 30, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned several Cuban individuals and entities in connection with actions to suppress peaceful, pro-democratic protests in Cuba that began on July 11, 2021. According to Treasury Secretary Janet Yellen, “The Cuban people are protesting
BIS Issues Interim Final Rule Expanding Certain Controls on Activities of U.S. Persons
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
State Department Re-Designates Cuba as State Sponsor of Terrorism
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
OFAC Sanctions Three Cuban Entities for Ties to Cuban Military
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
OFAC Restricts Remittances to and from Cuba to Exclude Entities on Cuba Restricted List
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