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Hotels Included in U.S. State Department Cuba Restricted List

As of Nov. 15, 2018, the State Department is adding 16 hotels owned by the Cuban military to the Cuba Restricted List (CRL).

As discussed in the November 2017 GT Alert, U.S. Implements President Trump’s Cuba Policy, the Department of State published the CRL, identifying certain entities and sub-entities that are “under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services.”

Except as otherwise authorized, no U.S. person may engage in a direct financial transaction with any entities and sub-entities identified on the CRL. Furthermore, any application to export or re-export items for use by entities or sub-entities identified on the CRL will be generally denied by the Department of Commerce’s Bureau of Industry and Security.

Among other entities added to the CRL, it now includes the brand new Grand Packard Hotel, a 321-room luxury hotel newly inaugurated in Cuba, managed by the Spanish brand Iberostar Hotel, which currently operates 27 hotels with 7,881 rooms on the island.

Cuban President Miguel Díaz-Canel personally attended the inauguration of the Packard Hotel, a little more than a year after the opening of the Kempinski’s Gran Hotel Manzana, showing the Cuban Government’s intent to make the island’s hospitality sector more upscale. Both the Packard and the Manzana (originally included in the first CRL) are now identified on the CRL.

This aspect of U.S.-Cuba relations continues to impact the hospitality industry.

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About this Author

Nelson Migdal, Greenberg Traurig Law Firm, Washington DC, Real Estate Law Attorney

Nelson F. Migdal is Co-Chair of the Hospitality Practice. He focuses his practice on the acquisition and disposition of hotels, hotel operations and management, franchising, licensing and branding, development and finance, large mixed-use projects, hotel management agreements, licensing agreements, commercial real estate acquisition and sale, and commercial leasing.

He has prepared and reviewed management and franchise agreements, purchase and sale agreements, multiple building covenants, and other documents related to the acquisition, financing...

Yosbel Ibarra, Greenberg Traurig Law Firm, New York and Miami, Corporate Law Attorney

Yosbel A. Ibarra serves as Co-Managing Shareholder of Greenberg Traurig’s Miami office, and as Co-Chair of the Latin American and Iberian Practice, which has been recognized as a leading Latin American practice by several publications, including Chambers & Partners. In 2014, the firm was named “Corporate/M&A – Law Firm of the Year” by Chambers Latin America.

Fluent in Spanish, Yosbel has spent his career advising clients doing business in the United States, Spain and across Latin America. He is consistently recognized by Chambers USA Guide for his knowledge of transactions involving Latin America and, in 2013, was listed by The M&A Advisor as one of its “40 Under 40”. Admitted to practice in both New York and Florida, he has led several important cross-border M&A transactions, as well as joint ventures and infrastructure projects, including public-private partnerships.

Yosbel is also a member of the steering committee for the firm’s Energy & Infrastructure practice.

Kara Bombach, Greenberg Traurig, Washington DC, International Trade and White Collar Defense Attorney

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals....

Osvaldo Miranda, Greenberg Traurig Law Firm, Miami, Foreign Legal Consultant
Foreign Legal Consultant

Osvaldo Miranda focuses his practice on general corporate and regulatory matters, including cross-border mergers and acquisitions, private equity transactions, and corporate financings.

An integral member of the firm’s Cuba Practice, Osvaldo has been recognized by Chambers Latin America for his knowledge of transactions involving Cuba. Prior to joining the firm, Osvaldo practiced law in Cuba as an attorney representing foreign investors and as a judge in one of Cuba’s commercial courts.