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ARTICLE · 12 JANUARY 2017

Smoother Sailing Ahead For Shippers After OFAC Clarifies Cuba Sanctions

Reed Smith
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A description of the 180-day rule can be found in 31 C.F.R. §515.207(a).

GlobalInternational Law
Leigh Hansson
Leigh Hansson
David Myers
David Myers
Jeffrey Orenstein
Jeffrey Orenstein
Jonathan Davey
Jonathan Davey
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On Friday, 6 January 2017, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) revised its Frequently Asked Questions (FAQs), adding five new FAQs (numbers 86-90) pertaining to vessel transactions with Cuba. The new FAQs come on the heels of a general licence issued by OFAC in October 2016 that significantly narrowed the scope of the so-called '180-day rule'— a restriction that prevents foreign-flag vessels from calling at U.S. ports for at least 180 days after calling at a Cuban port. See Reed Smith Client Alert, 17 October 2016. The five new FAQs discussed below provide clarity on several issues relevant to this and related rules.

FAQ No. 86: The 180-Day Rule and Goods/Passengers-on-Board Rule

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