November 8, 2017
Tomorrow, OFAC, BIS, and the State Department will take coordinated actions to implement the June 16, 2017 memorandum signed by President Trump which announced tighter restrictions on Cuba-related travel and transactions, in an effort to channel economic activities away from the Cuban military regime. Consistent with those announced in the presidential memorandum, the changes include, among others, ending individual (not group) “people-to-people” travel; prohibiting certain direct financial transactions with those identified on a list maintained by the State Department (“Cuba restricted list”) as being entities or subentities under the control of, or acting for or on behalf of, the Cuban military, security, and intelligence services, and with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba; establishing a general policy of denial for BIS license applications to export or reexport items for use by those identified on the State Department’s Cuba restricted list (unless excepted); revising OFAC’s definition of prohibited officials in the CACR; and simplifying and expanding BIS’ License Exception Support for the Cuban People (SCP).
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