pi_circular Compliance & regulationGeopolitical risk Skuld
US sanctions The nature of the relationship between Cuba and the US dates back to the some of the most intense periods of the cold war era. A thaw in relations under the Obama administration has led to some liberalisation of existing sanctions, but the Trump administration has adopted a more restrictive policy and in June 2017 introduced limitations on travel and transactions with entities related to the Cuban military, intelligence, or security services, including the Grupo de Administración Empresarial (GAESA). Members are well advised to consider the full picture before deciding to develop their trade in this direction. On 31 January 2025 the US Department of State has announced the re-creation of the Cuba Restricted List, which restricts transactions with some military and government-linked Cuban entities. The original list was created in the issued by President Trump in 2017 and was rescinded by President Biden in January 2025 . On 7 February 2025 a list of 237 entities is added to the Cuba Restricted List. The entities include: ministries holding companies hotels tourist agencies marinas stores entities serving the defence and security sectors The Bureau of Industry and Security (BIS) generally will deny applications to export or reexport items for use by entities on the Cuba Restricted List. On 8 June 2022 OFAC amended the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR) to increase support to people in Cuba. OFAC is also published a number of updated Frequently Asked Questions . The amended CACR: authorises group people-to-people educational travel to Cuba, removes restrictions on authorized academic educational activities, authorises travel to attend or organize professional meetings or conferences in Cuba, removes the $1,000 quarterly limit on family remittances, and authorizes donative remittances to Cuba. In addition to the above, the US has had, for over 50 years, a number of restrictions in place that mainly affec
INSIGHT: Cuba Sanctions
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