Cuba-Related Sanctions and Export Regulations: 10 Important Changes

New regulations will facilitate trade and investment in Cuba, including air travel and telecommunications to and within the island.

On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR) to implement President Obama’s Cuba policy changes announced on December 17, 2014. Here are 10 important takeaways from these changes, which took effect on January 16, 2015.

1. Impact on the Embargo -

The comprehensive US embargo of Cuba remains in effect, as required by statute. Without Congressional action, the Executive Branch does not have authority to lift the embargo entirely. Although the regulatory changes the Obama Administration implemented are the most significant modifications to the Cuba embargo since its inception, extensive US sanctions against Cuba continue. As the Department of the Treasury’s Office of Foreign Assets Control (OFAC) clarified, “[m]ost transactions between the United States, or persons subject to U.S. jurisdiction, and Cuba continue to be prohibited, and OFAC continues to enforce the prohibitions” of the CACR.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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