On April 24, 2019, the U.S. Department of State published an update to its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) adding five additional entities to the list.

On June 16, 2017, the President signed the National Security Presidential Memorandum-5 on Strengthening the Policy of the United States Toward Cuba (NSPM-5). Soon after, on November 9, 2017, pursuant to NSPM-5, both the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) published final rules amending the rules relating to Cuba.

Direct financial transactions with entities on the Cuba Restricted List are generally prohibited under the Cuban Assets Control Regulations (CACR), because the financial transactions would disproportionately benefit the Cuban military, intelligence, and security services at the expense of the Cuban people and private enterprise in Cuba. BIS also generally denies applications to export or re-export items for use by entities identified on the Cuba Restricted List.

The new update is the third update to the Cuba Restricted List, and it adds five additional subentities: (1) Hotel Santa Isabel (in Havana), (2) Hotel El Caney Varadero (in Varadero), (3) Melia Marina Varadero Apartamentos (in Varadero), (4) Aerogaviota (subentity of the Armed Forces Business Enterprises Group (GAESA)), and (5) Diving Center — Marina Gaviota (subentity of the Gaviota tourism group). The State Department will continue to update the list as needed.

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