Cuba Guidance July 2017

The changes to the U.S. policy on Cuba announced by the Trump Administration on June 16, 2017 do not take effect until The Office of Foreign Assets Control (OFAC) issues new regulations (somewhere between 30-90 days), but we expect that the new regulations will contain: a prohibition on all transactions between U.S. persons and “entities related to the Cuban military, intelligence, or security services” (i.e. Grupo de Administración Empresarial or “GAESA”, which controls around 60% of the Cuban economy); the elimination of the people-to-people travel exception for individuals; and, a change to the group educational travel permissions under the people-to-people exception, wherein the group trips must be organized “under the auspices of an organization that is subject to U.S. jurisdiction that sponsors such exchanges”.  OFAC will add entities owned by GAESA to their SDN list.  Individuals traveling to Cuba under OFAC general licenses, license exceptions or a specific license should use the Amber Road RPS tool to pre-screen Cuban entities.  Further guidance will be issued after OFAC issues their final changes to the regulations.  Please contact OEC with any questions.