Archives: Cuba Sanctions

Subscribe to Cuba Sanctions RSS Feed

New “Troika of Tyranny” Cuba Sanctions – More Bark Than Bite

Effective tomorrow the State Department is updating its Cuba Restricted List (press release here) to add 26 new subentities (along with amending the entries for 5 previously-listed subentities).  National Security Advisor John Bolton had previewed this action in a speech in Miami in which he labeled Cuba, Venezuela and Nicaragua the “Troika of Tyranny” and … Continue Reading

A ‘Modest Proposal’ for Cuba: OFAC, BIS and State Department Implement President’s New Cuba Policy

Effective November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR), respectively, to implement US Cuba sanctions policy changes President Trump announced in a presidential memorandum issued June … Continue Reading

Economic Sanctions Webinar

On Wednesday, November 15 at 12:00 PM EST, Anthony Rapa will be presenting “Recent Developments in Economic Sanctions: Russia, Iran, Venezuela, North Korea, and Cuba,” a webinar hosted by Federal Publications.  As described on the Federal Publications website: From “decertifying” the Iran deal to disputes with “Rocket Man,” the economic sanctions world has seen dizzying … Continue Reading

Lawsuits for Cuban Confiscated Property Still Suspended, For Now

On Friday, July 14, 2017, the Trump administration joined the administrations of Presidents Clinton, Bush, and Obama in suspending Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, also known as the Helms-Burton Act, a controversial provision that would authorize lawsuits in U.S. courts to recover damages related to confiscated property … Continue Reading

Sanctions Round-Up

Sanctions, sanctions, and more sanctions– everyone’s favorite tool of foreign policy sure has been making a lot of news lately.  Here’s a round-up of the latest sanctions analysis here at the International Compliance Blog: Russia: Peter Jeydel summarized the Russia sanctions bill that the Senate passed on June 14, while Alexis Early assessed the bill’s prospect for passage … Continue Reading

New Cuba Policy May Not Significantly Impact Many Sectors

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. … Continue Reading

Cuba Policy Changes Will Complicate New Business But Grandfather Existing Deals

In a much-anticipated speech on Cuba policy today, President Trump announced that, “effective immediately, I am canceling the last administration’s completely one-sided deal with Cuba.” That pronouncement notwithstanding, it appears that the Trump Administration’s new policy on Cuba (as set out in a Presidential Memorandum) will leave intact most of the changes made by the … Continue Reading

Congress Flexes Sanctions Muscles: Bills Target Iran, Russia, and Others

This month, Congress is considering an array of new sanctions-related legislation, and, in recent days, bipartisan support has grown for a bill that would potentially direct significant measures against Russia and Iran. Congress has also debated bills proposing new sanctions against North Korea, Hamas, Hezbollah, and both chambers have put forth multiple bills that would … Continue Reading

What to Expect for Economic Sanctions Under President Trump?

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading

What a Trump Administration Could Mean for International Regulatory Compliance

After the November 8, 2016 elections, Washington is preparing for a new Congress and the transition of power from eight years of the Democratic Obama administration to the Republican administration of President-elect Donald Trump.  As the incoming president builds his transition team and sets out his policy priorities, Steptoe will examine what these changes may … Continue Reading

Stephen Heifetz and Peter Jeydel on the Cuba Embargo in The Hill

Today, Steptoe’s Stephen Heifetz and Peter Jeydel were published in The Hill with an op-ed piece “Time to Finally End the Cuba Embargo.”  They argue that the President has the executive authority to lift most, if not all, of the embargo, in the wake of the 25th annual UN General Assembly vote condemning it.  For … Continue Reading

Further Loosening of Cuba Embargo Aims to Solidify Normalization of Relations

On October 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) published amendments to the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR).  These amendments took further steps to ease economic sanctions and export control restrictions on Cuba.  Along with these … Continue Reading

How the 2016 Election Will Impact Public Policy Developments

Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate.  In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade.  The … Continue Reading

Halliburton Settlement Shows Risks of Dealing with Entities Partially Owned by Sanctioned Entities

On February 25, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it concluded an enforcement action against Halliburton Atlantic Limited (“HAL”) and its affiliate Halliburton Overseas Limited (“HOL”) for alleged violations of the Cuban Assets Control Regulations (“CACR”). HAL and HOL are both Cayman Islands-headquartered subsidiaries of U.S. … Continue Reading

March Brings Latest Round of Cuba Sanctions Changes

On March 16, 2016, the Obama administration issued another round of amendments to the Cuban sanctions program. The Treasury Department’s Office of Foreign Assets Control and the Commerce Department’s Bureau of Industry and Security released revisions to the Cuban Assets Control Regulations and the Export Administration Regulations, respectively, that further ease sanctions and export restrictions … Continue Reading

More on the Recent Relaxation of Cuba Sanctions

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 … Continue Reading

BIS and OFAC Further Relax US Sanctions Against Cuba

On January 26, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the US Department of Commerce’s Bureau of Industry and Security (“BIS”) each announced continued relaxation of the US embargo of Cuba in furtherance of the Obama Administration’s new Cuba policy (more information here). OFAC revised the Cuban Assets … Continue Reading

Upcoming Webcast: 2015 Developments Regarding Economic Sanctions and Export Controls

Join us on Tuesday, December 15 for this complimentary webinar discussing economic sanctions, export control, and related developments over the past year.  Featured panelists include Steptoe International Compliance Blog contributors Alex Baj, Jack Hayes, Stephen Heifetz, Andy Irwin, Anthony Rapa, Meredith Rathbone, and moderator Ed Krauland. Date:   Tuesday, December 15, 2015 Time:   12:00 p.m. – 1:30 … Continue Reading

Summary of the Recent Easing of Cuba Sanctions

Last month, the Obama Administration continued its easing of the Cuba embargo, building on measures that it implemented in January.  In this round, OFAC and BIS amended restrictions targeted at Cuba to further authorize certain business activities in targeted sectors of the Cuban economy.  You can read more about the amendments here.  … Continue Reading

What’s Sanctions Got to Do with It? Why Understanding US Sanctions Is Critical for International Business Deals

What factors must companies consider when engaging in international mergers and acquisitions?  Although there has been much fanfare about President Obama’s announced relaxation of the Cuban embargo and plans to roll back Iran sanctions, many sanctions traps remain for the unwary. In their article “What’s Sanctions Got to Do with It?  Why Understanding US Sanctions … Continue Reading

BIS Removes Vestiges of Cuba’s State Sponsor of Terrorism Designation from the EAR, with Little Practical Impact

On July 22nd, the Department of Commerce’s Bureau of Industry and Security (BIS) revised the Export Administration Regulations (EAR) to implement the Secretary of State’s May 29, 2015 rescission of Cuba’s designation as a State Sponsor of Terrorism.  While Cuba’s removal from this list is a notable symbolic action, and provides some benefit to non-US … Continue Reading

What’s Next for the Cuba Embargo?

On July 1, President Obama announced that the United States and Cuba have agreed to reestablish diplomatic relations and open embassies in each other’s countries.  According to statements from the Obama Administration and the Cuban government, the respective embassies will open shortly after July 20. One interesting aspect of President Obama’s announcement was his call … Continue Reading