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ARTICLE · 14 NOVEMBER 2017

OFAC Toughens Cuban Sanctions Rules

Hogan Lovells Cadwalader
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The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") and the Department of Commerce Bureau of Industry and Security ("BIS")...

United StatesInternational Law

The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") and the Department of Commerce Bureau of Industry and Security ("BIS") published amendments to the Cuban Assets Control Regulations ("CACR") and Export Administration Regulations ("EAR") to implement the National Security Presidential Memorandum released by President Donald J. Trump in June 2017 (see OFAC amendments; OFAC FAQ; BIS amendments; Fact Sheet on the amendments). The amendments impose new restrictions on dealings related to Cuban military, intelligence, and security services, while still allowing travel to Cuba and commercial ties with the country – albeit with added limitations. The new restrictions take effect on November 9, 2017, and commercial engagements, travel, and other transactions initiated before that date will generally continue to be authorized.

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