President Trump announced, on June 16, 2017, that, “effective immediately, I am canceling the last administration’s completely one-sided deal with Cuba.” However, with two primary exceptions, the Presidential Memorandum setting out the new policy may leave in place most of the steps to ease the embargo that the Obama Administration and previous administrations had taken. First, the new policy will prohibit, with broad sector-specific exceptions, “direct financial transactions” with a certain list of entities linked to the Cuban military, intelligence, and security services, to be published by the US Department of State in the near future. Second, the new policy will re-impose some, but not all, of the limitations on “people-to-people” travel. While these two new restrictions could be substantial, their specific scope and impact will not be known until the US Departments of the Treasury, State, and Commerce publish the list and regulations required by the Presidential Memorandum.

For more information, please see our advisory.