THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

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Trump announces reversal of Obama’s rapprochement with Cuba

June, 2017

Presidential memorandum directs Commerce and Treasury to ‘initiate a process to adjust the current regulations’.

Trump announces reversal of Obama’s rapprochement with Cuba

President Trump announced on 16 June his intention to reverse some of the measures undertaken by the Obama administration to ease the longstanding US embargo on Cuba. His presidential memorandum directs the US Department of Commerce and the US Department of the Treasury to ‘initiate a process to adjust the current regulations’ within 30 days. The US Department of the Treasury’s Office of Foreign Assets (‘OFAC’) has issued FAQs, which emphasise that the 30-day deadline is only to begin the process of amending the Cuban Asset Control Regulations (‘CACR’) and that the changes will not take effect until the new or amended regulation are issued.

The proposed changes:

  • Prohibit transactions with the Cuban military. OFAC has clarified that it will not prohibit existing commercial arrangements.
  • Curtail self-directed individual travel to Cuba for US citizens for the purposes of ‘people to people’ educational activities.
  • Expand the category of officials of the government of Cuba that can be sanctioned by OFAC.

OFAC has not specified when the new or amended regulations will take effect; only that it ‘expects to issue its regulatory amendments in the coming months’.

 

President Trump’s announcement on Cuba can be found here:
https://www.whitehouse.gov/the-press-office/2017/06/16/national-security-presidential-memorandum-strengthening-policy-united

OFAC’s FAQs can be found here:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_20170616.pdf

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