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US – Commerce publishes interim final rule on Securing the Information and Communications Technology and Services Supply Chain; Comments due March 22, 2021

By , and 6 Mins Read

On January 19, 2021, the Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed Rules, please see our blog…

US State Department announces designation of Cuba as a State Sponsor of Terrorism

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On January 11, 2021, the US State Department published a press release announcing Cuba’s designation as a State Sponsor of Terrorism (“SST”) for allegedly providing support for acts of international terrorism in granting safe harbor to terrorists. Cuba was originally designated as an SST in 1982 but was delisted in 2015 by President Barack Obama. Cuba’s SST designation follows increasingly stringent sanctions imposed by the US Government including restriction on remittances to Cuba and further restrictions on…

US – State updates the List of Entities and Subentities Associated with Cuba (Cuba Restricted List)

By 1 Min Read

On January 8, 2021 the Department of State published in the Federal Register an update [Public Notice 11296] to its List of Restricted Entities and Subentities Associated With Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR). The Department of Commerce’s Bureau of Industry and Security (BIS) generally will deny applications to export or reexport items for use by entities or subentities on the Cuba…

UK government publishes guidance on UK implementation of EU Blocking Regulation post-Brexit

By and 3 Mins Read

The UK Department for International Trade has recently published guidance on how the UK will transpose and implement the EU Blocking Regulation (Council Regulation (EC) 2271/96) post-Brexit. The EU Blocking Regulation seeks to counter the extra-territorial impact of certain US sanctions (the “proscribed US sanctions”), currently in respect of Iran and Cuba (please see our previous blog post on updates of the EU Blocking Regulation in respect of Iran here). During the transition period, the EU…

US Government restricts remittances to Cuba

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On October 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published a final rule amending the Cuban Assets Control Regulations (CACR) restricting certain remittance-related transactions to and from Cuba (the “Final Rule”). OFAC also published updated and new Frequently Asked Questions (FAQs) related to transactions with Cuba. Significantly, the recent amendments will have the practical effect of making remittances to Cuba more difficult. The Final Rule becomes effective on November 26, 2020 and is…

US Government further tightens Cuban sanctions targeting Cuban travel, hotels, cigars and rum

By , and 3 Mins Read

On September 24, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published a Final Rule in the Federal Resister that amended the Cuban Assets Control Regulations (CACR) to further implement the President’s foreign policy to deny the Cuban regime sources of revenue. Major elements of the changes include: Professional (Including Business) Meetings and Conferences: The Final Rule amends a CACR general license to eliminate the authorization for CACR parties to attend or organize professional (including business)…

US – State issues Cuba Prohibited Accommodations and updated Cuba Restricted Lists

By 1 Min Read

On September 28, 2020, the State Department published in the Federal Register the initial Cuba Prohibited Accommodations List [Public Notice 11217] identifying properties subject to additional prohibitions with respect to certain lodging-related transactions under the Cuban Assets Control Regulations (CACR). The State Department will update the CPA List periodically via the Federal Register and on its website. On September 29, 2020, the State Department published in the Federal Register an update to its List of…

US Government suspends private charter flights between the United States and Cuba

By , , , , and 3 Mins Read

On August 13, 2020, US Secretary of State Mike Pompeo issued a statement requesting that the US Department of Transportation (DOT) suspend private charter flights to all Cuban airports. This action will suspend all charter flights between the United States and Cuba over which the DOT exercises jurisdiction, except for authorized public charter flights to and from Havana and other private charter flights authorized for limited purposes. Secretary Pompeo’s statement cites the Administration’s intent to deny economic resources to…

State updates Cuba Restricted List

By 1 Min Read

On June 12, 2020 the Department of State published in the Federal Register an update [Public Notice 11136] to its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR). The Department of Commerce’s Bureau of Industry and Security (BIS) generally will deny applications to export or reexport items for use by entities or subentities identified by the…

US Government expands restrictions against Cuba: BIS further restricts exports to Cuba and DOT suspends scheduled air service for Cuba

By 5 Mins Read

On October 21, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to further restrict exports and reexports of items to Cuba (“the Amendment“). According to BIS, the Amendment was made to further restrict the Cuban government’s access to items subject to the EAR, thereby supporting the US government’s national security and foreign policy decision to hold the Cuban regime accountable for its repression of the Cuban people…