THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 84, November 2019

BIS further restricts exports to Cuba 

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  By Michael T. Gershberg, Justin A. Schenck and Avani Uppalapati, Fried Frank www.friedfrank.com   On 21 October 2019, the US Department of Commerce’s Bureau of Industry and Security (‘BIS’) published a final rule1 further restricting the export and reexport of items to Cuba, including (1) a reduction in the de minimis level applicable to Cuba, (2) limiting the export of aircrafts to government-owned airlines, and (3) tightening the rules for certain donations to Cuba. The rule was issued in response to Cuba’s continuing support for the Maduro regime in Venezuela and human rights violations in Cuba. It also represents...

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