As previously mentioned, more changes to the regulations governing the U.S. embargo against Cuba were announced by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) on January 27, 2016. The OFAC and BIS measures continue to ease the decades-old embargo by amending the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR).
Changes to the CACR include provisions allowing certain kinds of trade finance, and the addition of general licenses for specified informational materials, vessels and aircraft, travel, and humanitarian projects. BIS has amended the EAR to expand the types of goods for which it will grant export licenses, including certain items related to telecommunications, civil aviation, agriculture, human rights and civil society organizations, and US news bureaus in Cuba. In addition, BIS will approve certain transactions with state-owned enterprises in Cuba which it deems aim to “meet the needs of the Cuban people.”
Even with this further relaxation of the regulations, the U.S. embargo against Cuba largely remains in place, and careful analysis of the relevant laws is necessary to ensure compliance with the various requirements and exceptions. For a full analysis of the new provisions, please click here.