On September 6, 2019, the US Treasury Department Office of Foreign Assets Control (OFAC) announced that it is amending the Cuban Assets Control Regulations (CACR) to further financially isolate the Cuban government and implement President Trump’s June 2017 National Security Presidential Memorandum (NSPM) Strengthening the Policy of the United States Towards Cuba (the “CACR Amendment”). The CACR Amendment (1) removes the authorization for banks subject to US jurisdiction to process pass-through or “U-turn” transactions, and (2) eliminates…

On Tuesday, June 4, 2019, the Trump Administration announced additional changes to its Cuba policy, further restricting group people-to-people educational travel and limiting the types of aircraft and vessels authorized to travel to Cuba on temporary sojourn. Tuesday’s actions are intended to prevent travel from the United States to Cuba from enriching the Cuban military, intelligence, and security services. These changes, which took effect on June 5, 2019, are a further step toward implementation of…

On April 24, 2019, the Department of State published in the Federal Register a notice updating its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under §515.209 of the Cuban Assets Control Regulations (CACR). This Cuba Restricted List is also considered during review of license applications submitted to the Commerce’s Bureau of Industry and Security (BIS) pursuant to the Export Administration Regulations (EAR). BIS will generally deny applications to export or re-export items for use by entities or subentities identified on the Cuba Restricted List.

On November 15, 2018, the State Department’s Bureau of Economic and Business Affairs released a list of entities and subentities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. For information regarding the prohibition on direct financial transactions with these…

On September 10, 2018, the President signed Presidential Determination No. 2018–11 of September 10, 2018 Continuation of the Exercise of Certain Authorities Under the Trading With the Enemy Act, which continues the exercises of Trading With the Enemy Act authorities with respect to Cuba until September 14, 2019, as implemented by the Cuban Assets Control Regulations, 31 C.F.R. part 515.