January 17, 2022

Volume XII, Number 17

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US Department of Commerce Further Tightens Cuba Sanctions

On October 18, 2019, the Bureau of Industry and Security (BIS) of the US Department of Commerce announced that it will further restrict the Cuban regime’s access to goods, including commercial aircraft. This action is in response to Cuba’s domestic situation, as well as its support of the Maduro regime in Venezuela. 

The expanded sanctions revoke the existing license for aircraft leases to Cuban state-owned airlines, amend the licensing policy with the establishment of a denial for leases of aircraft to Cuban state-owned airlines, and clarify that aircraft and vessels are not eligible for the License Exception Aircraft and Vessels (AVS) if they are leased to or chartered by a national of Cuba. Additionally, the sanctions establish a general 10% de minimis level of US-origin content for Cuba, revise License Exception Support for the Cuban People (SCP) to render the Cuban government and Communist Party ineligible for donations of items for use in scientific, archaeological, cultural, ecological, educational, historic preservation or sporting activities, and remove authorization for promotional items that benefit the Cuban government. Finally, the revision clarifies the scope of telecommunication items, limited only to infrastructure to improve the freedom of information that the Cuban government is able to receive without a license.

© Copyright 2022 Squire Patton Boggs (US) LLPNational Law Review, Volume IX, Number 305
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