Shifting Course: Expanding the Scope of Permissible Cuba Transactions

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The Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued its first set of amendments to the Cuban Assets Control Regulations (“CACR”) to begin implementing a major policy shift in United States–Cuba relations, as announced by the President on December 17, 2014. Concurrently, the Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to authorize certain exports to Cuba. These amendments became effective on January 16, 2015. Although these amendments represent the liberalization of certain Cuba sanctions, it is important to note that the basic sanctions in effect against Cuba remain in place.

The CACR amendments authorize a wide range of activities pursuant to general licenses. These include: (1) certain categories of travel to Cuba (excluding general tourism) and related services; (2) U.S. financial institutions establishing correspondent accounts at Cuban financial institutions to facilitate the processing of authorized transactions; (3) expanding permissible telecommunications activities; (4) increasing the amount of remittances that may be sent to Cuba; and (5) permitting non-U.S. subsidiaries of U.S. companies to engage in certain transactions with Cuban nationals located outside of Cuba.

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