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
OFAC Amends Cuba Sanctions, Further Restricting Activities with Cuba
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;…
State Department Updates Cuba Restricted List
Shortly after taking office, President Donald Trump announced a foreign policy shift toward Cuba with the issuance of National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba (NSPM). In announcing President Trump’s revised policy in June 2017 (see Trump and Trade Update of June 20, 2017), the…
OFAC Issues Fact Sheet on Providing Humanitarian Aid to Combat COVID-19 Under Various Sanctions Programs
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…
President Trump Touts USMCA and “Phase One” China Deal in Third State of the Union Address
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…
United States Tightens Sanctions on Cuba, Lowers De Minimis Level of U.S. Content in Foreign Goods
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…
United States to Further Tighten Cuban Sanctions
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…
Commerce Adds 46 Huawei Technologies Co., Ltd. Entities to its Entities List; Extends Temporary General License
In a Federal Register notice published on August 21, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it has added 46 non-U.S. affiliates of Huawei Technologies Co., Ltd. (Huawei) to the Entity List because they “pose a significant risk of involvement in activities contrary to the national security or foreign…
Trump Administration Further Restricts Travel to Cuba
On June 5, 2019, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) undertook coordinated actions to further restrict travel to Cuba “in order to hold the Cuban regime accountable for its repression of the Cuban people and its support of the…
Trump Administration Implements Further Sanctions Against Cuba, Venezuela and Nicaragua
In a series of actions on April 17, the Trump administration announced the implementation of additional sanctions on the “Troika of Tyranny” in the Western Hemisphere (see Trump and Trade Update of November 16, 2018). President Donald J. Trump and his National Security Advisor John Bolton have long held that Cuba, Venezuela and Nicaragua…