On January 16, 2015, the United States amended existing regulations to implement the changes announced by President Obama on December 17, 2014, liberalizing US sanctions and export controls targeting Cuba. As a result, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) amended its economic sanctions regulations and the US Department of Commerce's Bureau of Industry and Security (BIS) amended its export control regulations relating to Cuba. These amended regulations became effective on Friday, January 16, 2015.
According to the United States, the purpose of the changes is to promote political and economic freedom for the Cuban people by easing sanctions related to travel, remittances, trade, banking and communications. OFAC sanctions were liberalized to authorize the following Cuba-related activities: (i) certain financial transactions, (ii) certain types of travel and travel services, including insurance, (iii) certain trade transactions, (iv) broader remittances, (v) additional transactions involving telecommunications and Internet-based services and (vi) expanded US and foreign governmental activities. US export controls were eased to authorize the export and reexport of certain items to Cuba. Although the measures signal the most significant change in US economic and trade policy towards Cuba to date, the Cuba embargo remains in place and most transactions between the United States or persons subject to the jurisdiction of the United States and Cuba continue to be prohibited. Therefore, it is all the more important that parties contemplating activities in Cuba undertake rigorous review of potential transactions to ensure compliance with both BIS and OFAC's amended regulations.
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