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ARTICLE · 24 JULY 2015

U.S. Export Controls Amended To Eliminate

Hughes Hubbard & Reed LLP
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The U.S. Department of Commerce, Bureau of Industry and Security ("BIS") today published a rule removing Cuba as a State Sponsor of Terrorism under the Export Administration Regulations ("EAR").

United StatesInternational Law
F. Amanda DeBusk
F. Amanda DeBusk
Melissa Duffy
Melissa Duffy
Alan Kashdan
Alan Kashdan
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The U.S. Department of Commerce, Bureau of Industry and Security ("BIS") today published a rule removing Cuba as a State Sponsor of Terrorism under the Export Administration Regulations ("EAR"). See "Cuba: Implementing Rescission of State Sponsor of Terrorism Designation," 80 Fed. Reg. 43314 (July 22, 2014). With this change, foreign companies not owned or controlled by U.S. persons can send to Cuba foreign-made products with up to 25% U.S. content. Previously, foreign companies could not send products with more than 10% U.S. content to Cuba. As a practical matter, this makes it easier for foreign companies with Cuban customers to use U.S. products in their goods. In addition, the change makes it easier for U.S. companies to use export license exceptions that apply to replacement parts, certain government end users, hand-carried equipment and aircraft. However, the comprehensive trade embargo against Cuba still applies to U.S. persons and the foreign subsidiaries they

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