News & Analysis as of

Cuba Export Administration Regulations (EAR)

Foley Hoag LLP - White Collar Law &...

Review of Sanctions and Export Control Developments in 2021 and What to Expect in 2022

This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more

Husch Blackwell LLP

U.S. Government Imposes Sanctions And Issues Joint OFAC/BIS Telecommunications Fact Sheet To Support Cuban Protests

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During the past month, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has issued three separate rounds of Specially Designated Nationals & Blocked Persons List (“SDN List”) designations in order...more

ArentFox Schiff

Sleeper Trump Rule on ‘Military-Intelligence End Uses or Users’ Goes Into Effect

ArentFox Schiff on

Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more

BCLP

Recent Changes to the List of State Sponsors of Terrorism: What Impact Do They Have On Export Compliance?

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Shortly before the end of his term, the Trump Administration made changes to the List of State Sponsors of Terrorism, removing Sudan and putting Cuba back on. What do the changes mean for Sudan? With the sanctions...more

Dorsey & Whitney LLP

Trump Administration Revises List of State Sponsors of Terrorism

Dorsey & Whitney LLP on

On January 11, Secretary of State Michael Pompeo announced the Trump Administration in its final week in office is returning Cuba to the official State Department list of state sponsors of terrorism. Cuba will thus re-join...more

ArentFox Schiff

US Export Controls: Business as Usual?

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Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more

Lowenstein Sandler LLP

Compliance Matters: What Executives Should Know About International Shipments

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As trade compliance gains more traction, US regulators have made it clear that having compliance policies in place is critical, regardless of the company size or the industry. The implementation of such compliance programs...more

Foley Hoag LLP

Cross-Border Compliance Update: June - July 2020

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Hong Kong Updates and Alerts - New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended - On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Foley Hoag LLP

Cross-Border Compliance Update: October 2019

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Additional Restrictions on Exports to Cuba - On October 15, 2019, the Department of Commerce (DOC) amended the Export Administration Regulation (EAR) to further restrict the export and reexport of items to Cuba. The...more

Holland & Hart LLP

U.S. Hits Cuba With Another Round of Sanctions – De Minimis Threshold Dropped to 10 Percent

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On October 21, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) imposing new sanctions on Cuba for human rights abuses and for its support of...more

Hogan Lovells

BIS issues final rule restricting additional exports and reexports to Cuba

Hogan Lovells on

On 21 October 2019 the Bureau of Industry and Security (BIS) issued a final rule amending Cuba-related provisions in the Export Administration Regulations (EAR). The new rule further restricts exports and reexports of...more

ArentFox Schiff

BIS Imposes Additional Cuba Trade Restrictions and Restricts Use of Temporary Sojourn License Exception for Multiple Countries

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BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...more

Akerman LLP

New Directives Curtail U.S. Travel To Cuba

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As noted in Helms-Burton Title III Comes to Life, U.S.–Cuba relations have been deteriorating steadily since 2017, a trend that has accelerated recently in response to developments in Venezuela. In addition to Title III,...more

Holland & Knight LLP

Trump Administration Eliminates People-to-People Travel to Cuba - Changes in Regulations Will Have Major Effect on Private...

Holland & Knight LLP on

• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce's Bureau of Industry and Securities (BIS) announced changes to the Cuban Assets Control Regulations (CACR)...more

Akin Gump Strauss Hauer & Feld LLP

New Cuba Sanctions Measures Prohibit “People to People” Travel to Cuba and Restrict Use of Commercial Aircraft and Recreational...

In a June 4 announcement, the Trump administration further ratcheted up U.S. sanctions and export controls against Cuba by prohibiting group “people-to-people” travel to Cuba and the use of noncommercial aircraft and...more

Pillsbury - Global Trade & Sanctions Law

Cuba Travel Update: U.S. Regulators Amend Key Rules

On June 5, 2019, the Department of Commerce Bureau of Industry and Security (BIS) amended an important license exception which generally permitted the temporary sojourn of civil aircraft and vessels to Cuba.  ...more

Akin Gump Strauss Hauer & Feld LLP

Treasury, State and Commerce Implement Regulations Pursuant to the Trump Administration’s Cuba Policy

• On November 9, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) took coordinated...more

Jones Day

Revised U.S. Regulations Support Cuba's Private Sector, but Travel Restrictions Remain

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The Situation: Regulations implementing tightened U.S. policy towards engagement with Cuba have rolled back a number of Obama-era initiatives and are effective immediately. The Result: Provisions that encourage Cuban...more

Skadden, Arps, Slate, Meagher & Flom LLP

In Directional Shift, US Implements New Restrictions on Cuba

On November 8, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS), and the U.S. Department of State announced...more

Baker Donelson

Cuba Sanctions Guidance: November 2017 Update

Baker Donelson on

On November 9, 2017, changes to the United States' Cuba Sanctions program went into effect, as the Department of Treasury's Office of Foreign Assets Control (OFAC) and the Department of Commerce's Bureau of Industry and...more

Dechert LLP

US Implements Changes to Cuba Sanctions

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The U.S. Government this week announced changes to U.S. sanctions against Cuba to implement various policy changes announced by President Trump in July 2017 (for additional background, see our prior OnPoint from June 2017)....more

Miller Canfield

Status of Key U.S. Sanction Programs

Miller Canfield on

Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more

Baker Donelson

Treasury Department Issues FAQ on Impact of Cuba Policy Shift

Baker Donelson on

On June 16, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a press release answering 12 "Frequently Asked Questions" ahead of President Trump's announcement of a revised U.S. policy...more

Morgan Lewis

President Trump Announces Rollback on Obama-era Cuba Sanctions Easing

Morgan Lewis on

Changes to unwind will not take effect until new regulations are issued. On June 16, US President Donald Trump announced his decision to revoke some—but not all—of the relaxations in Cuba sanctions initiated under former...more

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