Commerce Tightens Restrictions On Cuba

The Administration tightened export regulations regarding Cuba, effective October 21, 2019. The changes are generally targeted at Cuban government-owned enterprises, and according to the Commerce Department press release are intended to “hold the Cuban regime accountable for its repression of the Cuban people and its support for the Maduro regime in Venezuela.”

Aviation

The amended regulations replace the Bureau of Industry and Security’s (BIS) general policy of approval with a presumption of denial of licenses for the sale or lease of aircraft to Cuban state-owned airlines. To demonstrate ownership, any aircraft departing for Cuba must retain certain enumerated “indicia of control,” including the right to perform principal maintenance on the aircraft, place of registration, and a minimal transfer of technology.