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 changes create a new general policy of denial for any leases of aircrafts to Cuban state-owned airlines, and clarifies that aircrafts and vessels are not eligible for the Aircraft, Vessels and Spacecraft License Exception if leased or chartered by a Cuban national.

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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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