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September 18, 2015: Cuban Assets Control Regulations updated
On Friday, President Obama issued changes to a number of elements in the sanctions regime against Cuba, including travel, telecommunications, Internet, business operations and remittances. The changes...
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OFAC’s CACR changes FAQ, Part I: Embargo basics
Where can I find the amendments to the Cuban Assets Control Regulations (CACR)? Please see the Federal Register. When are the most recent amendments to the CACR effective? The most recent amendments...
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OFAC’s CACR changes FAQ, Part II: Travel
II. Travel For questions regarding travel and accompanied baggage between the United States and Cuba, please see the specific guidance on OFAC’s webpage. What are the travel authorizations in the Cuba...
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OFAC’s CACR Changes FAQ, Part 3: Remittances
IV. Remittances 37. What changes have been made with respect to authorized remittances by U.S. persons to Cuba? Effective September 21, 2015, the dollar limits on generally licensed donative...
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OFAC’s CACR changes FAQ, part 4: Banking
V. Banking Are authorized travelers permitted to open bank accounts in Cuba? Under a new general license, persons subject to U.S. jurisdiction who are traveling to Cuba pursuant to one of the 12...
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OFAC’s CACR changes FAQ, Part 5: Trade/Business
Is Cuba open for U.S. business and investment? Persons subject to U.S. jurisdiction are prohibited from doing business or investing in Cuba unless licensed by OFAC. An OFAC general license authorizes...
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OFAC’s CACR changes FAQ, part 6: Telecommunications
VII. Telecommunications 61. What types of telecommunications services are recently authorized under general license? Effective January 16, 2015, OFAC issued an expanded general license which, subject...
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OFAC’s CACR changes FAQ, part 7: Third Party Effects
VIII. Third-Country Effects Are Cuban nationals located outside of Cuba still considered blocked? Yes, but any individual Cuban national who can establish that he or she has taken up permanent...
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OFAC’s CACR changes FAQ, part 8: Miscellany
IX. Miscellaneous 69. Are specific licenses still required for transactions relative to the administration of a Cuban estate? Previously, a specific license was required for certain estate-related...
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OFAC Enforcement Action against Credit Agricole
This was part of a much larger settlement (approximately $787 million) – OFAC's piece was about $329.5 million. There were a total of 4297 total violations – primarily of the Sudanese sanctions...
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October 27, 2015: Gil Tours Settles for $43,875 OFAC Fine
Between October 2009 and August 2010, Gil Tours violated the Cuban Asset Control Regulations by providing travel-related services for 191 persons. The base penalty for these non-voluntarily...
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Buh-bye! OFAC calls it quits with Cuba, Narcotics, Iran listings
Earlier today, OFAC removed the following sanctions listings from its SDN List: URREGO ESCUDERO, Carlos Agustin (a.k.a. BENALCAZAR FURMAN, Moshe), Colombia; DOB 19 Feb 1976; citizen Colombia; Cedula...
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November 25, 2015: New Cuba Travel-Related FAQ question 52
On Wednesday, OFAC published an updated version of its Cuban sanctions Frequently Asked Question (FAQ) document. The new question (#52) is about banks' processing of authorized travel transactions vis...
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December 21, 2015: OFAC Updates Cuba Program FAQ
In particular, questions 57-61 regarding insurance were updated: 57. Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S....
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January 26, 2016: Amendments to Cuban regulations being published today
Today (Wednesday, January 27th), OFAC is issuing amendments to the Cuban Assets Control Regulation (CACR) in line with the December 2014 policy changes announced by President Obama “intended to further...
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Amendments to Cuban Asset Control Regulations: The Layman Section
Breaking this up because it's an 18 page PDF. This will make it easier to digest…. And I'm going to skip the sections that non-lawyers will not understand with the current CACR in front of them....
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OFAC Enforcement Action: WATG Holdings & subsidiary run afoul of Cuban sanctions
The firm provided architectural design services for a Cuban hotel between 2009 and 2010, for which it was paid $284,515. The settlement? Roughly half – $140,000, for a non self-disclosed, non-egregious...
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Cuban Asset Control Regulation Amendments, Part 2
Some flavor from the amendments document, in relatively clear English: (d) General license for travel-related transactions incident to exportation or reexportation of certain items. (1) The...
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Cuban Asset Control Regulations, Part 3
§ 515.567 Public performances, clinics, workshops, athletic and other competitions, and exhibitions. (a) General license for amateur and semi-professional international sports federation competitions....
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October 27, 2015: Gil Tours Settles for $43,875 OFAC Fine
Between October 2009 and August 2010, Gil Tours violated the Cuban Asset Control Regulations by providing travel-related services for 191 persons. The base penalty for these non-voluntarily...
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