Yesterday, OFAC announced amendments to the Cuba embargo that will further restrict the ability of U.S. companies to process remittances to or from Cuba. Specifically, the new rules prohibit U.S. companies from processing...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) continues to rack up settlements. Two travel insurance companies recently settled OFAC enforcement actions for violations of the Cuban Embargo....more
On December 20, 2018, Major League Baseball (“MLB”), Major League Baseball Players Association (“MLBPA”), and the Cuban Baseball Federation (“FCB”) announced an Agreement allowing Cuban-based baseball players to sign with MLB...more
By lifting the suspension of the private right of action afforded by Title III effective May 2, 2019, the Trump administration has cleared the way for civil lawsuits against persons or companies trafficking in property...more
If the suspension of Title III of the Helms-Burton Act is not extended after April 17, all companies with a US presence—including US subsidiaries of foreign parent companies—that “profit” from property confiscated by the...more
Dear Friend of Snell & Wilmer: The past year brought significant changes across a variety of political, legal, and policy spheres, and the world of U.S. international trade law was no exception. This edition of the...more
American Honda Finance Corporation (American Honda) has settled with the Office of Foreign Assets Control (OFAC) over potential civil liability for 13 violations of the Cuban Assets Control Regulations (CACR), which that...more
In our last post, we made a few cocky predictions about the new Trump Administration’s Cuba policy. We correctly asserted that the President would try to chart a narrow course between the Scylla of conservative Cuban-American...more
On June 16, 2017 during a speech in Miami, President Trump announced changes to US sanctions targeting Cuba. The speech announced two substantial changes to the previous administration’s Cuban sanctions regime: first, the new...more
On Friday, June 16, President Trump announced policy changes towards Cuba while speaking in Miami. Trump’s new policy directive reverses many of the Obama administration’s policies with Cuba. ...more
Questions continue to swirl around the future of U.S.-Cuba policy as recent reports of a Trump Administration plan to strengthen Cuba sanctions surfaced over the weekend. These reports should be assessed against the backdrop...more
According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more
As much of the world now knows, beginning in January 2015, the Obama Administration began easing some of the sanctions that have been imposed on Cuba for generations. Since that easing, there has been a great deal of interest...more
Throughout the eight years of the Obama administration, the development and implementation of economic sanctions was a key element of U.S. foreign and national security policy. This strategy continued into the post-election...more
SHINING LIGHT INTO THE HEART OF DARKNESS:An Update on the Cuban Embargo - I. Executive Summary - Sixty years after the imposition of the Cuban Embargo, the orthodoxy and ideology that caused it to persist are no...more
U.S. embargoes and economic sanctions on countries such as Iran, Russia and Cuba were discussed at length by both candidates during the 2016 Presidential campaign, and President-Elect Trump has stated that he intended to...more
After the announcement of Fidel Castro’s death on November 26, 2016, President Barack Obama sent a message to the Cuban people highlighting his administration’s efforts to improve relations between the United States and Cuba....more
Effective October 17, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the U.S. Commerce Department’s Bureau of Industry and Security (BIS) have expanded the scope and nature of transactions...more
Bob Dylan won the Nobel Prize for literature. Those were words I never thought I would see in the same sentence, let alone write in the same sentence. Yet here we are, the first rock and roller to win the Nobel Prize. While...more
With news of the resumption of commercial aviation flights to Cuba, and other changes in the Cuba embargo accomplished through Presidential executive order, it would appear at first blush that the time is ripe to travel to...more
The loosening of the U.S. trade embargo on Cuba has generated significant discussion regarding the country's potential for economic transformation. Most analysts agree that Cuba will be a very different country 10 years from...more
The opening of Cuba to greater commercial and financial activity offers many possibilities for U.S. financial institutions but, with those possibilities, comes a responsibility to meet the complex compliance challenges that...more
For the first time since 1978, a U.S. Cruise line sailed to and docked in Havana, Cuba. On May 2, 2016, Fathom, a Carnival Corporation brand, became the first U.S. cruise line to take advantage of regulatory changes...more
On April 21, 2016, the Department of Treasury’s Office of Foreign Assets Control (OFAC) updated its FAQ document related to Cuba. This document contains answers to several questions regarding information about Cuba such as...more
On March 20, 2016, President Obama became the first United States president in almost 90 years to visit the island of Cuba, located a mere 90 miles from the coast of Florida—signaling not only a renewed diplomatic...more