Navigating the Complex Legal Issues
When Doing Business With Cuba
On December 17, 2014, President Obama made a historic announcement: “Today, the United States is taking historic steps to chart a new course in our relations with Cuba and to further engage and empower the Cuban people.” By January 16, 2015, both the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) amended its Cuban Assets Control Regulations, and the U.S. Department of Commerce’s, Bureau of Industry and Security (BIS) amended the Export Administration Regulations with a “Support for the Cuban People” license exception. Both OFAC and BIS’s new rules were effective as of January 16, 2015. OFAC and BIS issued additional new rules on June 15, 2015, July 22, 2015, September 21, 2015, January 27, 2016, March 15, 2016, October 14 2016, and November 9, 2017. The additional rules effective in 2017 reflect the Trump Administration’s position on doing business with Cuba.
The new changes announced provide a revision to the regulations and have a substantial impact on travel, telecom, building materials and agricultural equipment, financial services, personal importations. It is important to note the Cuban Embargo still stands, it will take an act of Congress to remove the Embargo. You should ensure you consult with a Customs and Trade Expert before engaging in ANY transactions with Cuba. Diaz Trade Law stays abreast of all of the changes to U.S. law and keeps our clients in tune with the changes and business opportunities.
New Regulations by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS)