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The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more
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
The U.S. Department of Commerce (Commerce) recently announced its "apparent" need for public comment on key aspects of a mechanism that would license or preclear certain information and communications technology and services...more
Back in May 2019, the Trump Administration issued Executive Order 13873, which was meant to police the use of certain information and communications technology and services (ICTS) purchased from "foreign adversaries." Then,...more
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
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
n late January 2021, the U.S. Department of Commerce issued an Interim Final Rule (Interim Rule) that would empower the Department to prohibit, mitigate and unwind certain categories of transactions with certain foreign...more
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
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
• 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
The Trump Administration has made good on its promise to cut back on the liberalized Cuban policy implemented by the Obama Administration with a new regime that introduces new travel restrictions as well as broad prohibitions...more
Overview of US and EU Trade Sanctions - Following is a summary of the current US and EU sanctions that restrict trade with and/or investment in certain countries, “Specially Designated Nationals” (SDNs) and “Blocked...more
We all know that export regulations cannot keep up with reality. Reforms are happening very quickly, especially regarding Cuba. So, here’s a new procedure we just discovered. Perhaps it can help you if you are ever similarity...more
The Obama Administration’s move to normalize relations with Cuba continues to spur commercial interest in the island. Despite the U.S. economic embargo on Cuba, regulatory changes announced by the U.S. Department of the...more
As President Obama moves forward to revise policies toward Cuba, opportunities for carriers on the U.S.-route continue to arise. In addition to revisions to relevant FCC regulations, which we’ve covered here and here,...more
This is an exciting time to think about deploying communications services to Cuba. The Federal Communications Commission is (“FCC”) seeking comment on a proposal to eliminate one of the few remaining restrictions on...more
In a recent flurry of activity to implement the President's policy agenda to reestablish relations with Cuba, federal agencies are moving forward with a wave of proceedings and regulations with specific provisions geared...more
Although Congress has remained cautious of taking any action to ease the American-imposed embargo on the majority of business interactions with Cuba, President Obama’s administration continues to push forward with the...more
On September 21, 2015, 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 Security (BIS) amended their respective Cuba regulations to...more
New rules came out on September 21, 2015 from both the Commerce and Treasury Departments. Although for the most part these changes only slightly broaden or clarify pre-existing exceptions to the embargo against Cuba, they...more
Policy changes announced by the Obama administration on September 18 will allow U.S. food and agriculture companies, U.S. telecommunications companies and U.S. building material supplier companies to establish a business...more
However, the new transaction rules leave the embargo largely in effect. Early this week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and...more
Effective September 21, the U.S. Department of Treasury amended its Cuban Assets Control Regulations (CACR), providing further Cuba sanctions relief. In a coordinated action, the U.S. Department of Commerce simultaneously...more
Amendment triggers change in EAR de minimis level for controlled US-origin content in foreign made products. On April 14, US President Barack Obama submitted to Congress the statutorily required report indicating the...more
As you know there are ongoing changes to the Cuba export regulations. President Obama announced the reopening of the U.S. embassy in Havana and a Cuban embassy in Washington. The Commerce Department will remove Cuba from list...more