January 16, 2018

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U.S. Implements President Trump’s Cuba Policy

On Nov. 8, 2017, the U.S. Government announced new regulations in furtherance of the Trump Administration’s policy regarding Cuba.

In June 2017, President Trump published his National Security Presidential Memorandum “Strengthening the Policy of the United States Toward Cuba” (NSPM), which announced modification of U.S. policy with respect to Cuba to target the Cuban military, intelligence, and security agencies.  In the NSPM, President Trump emphasized the need to promote the flow of economic benefits to the Cuban people, rather than to its military.  The NSPM further directed the Commerce, State, and Treasury Departments to take various actions implementing the new policy.

Accordingly, regulations were released this week by the U.S. Department of State, Department of Treasury’s Office of Foreign Assets Control (OFAC), and Department of Commerce’s Bureau of Industry and Security (BIS) to implement the NSPM, and clarify the limitations imposed on U.S. persons wishing to travel to or do business in Cuba.

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About this Author

Sonali Dohale, Greenberg Traurig, compliance counseling lawyer, environmental due diligence attorney

Sonali Dohale focuses her practice on compliance counseling, environmental due diligence and environmental litigation under state and federal statutes. Sonali’s experience at government regulatory agencies and her background in civil and environmental engineering help give her insight into both the legal and technical challenges faced by her clients.

Kara M Bombach, International Trade Attorney, Greenberg Traurig, export goods counsel, global technology lawyer, anti-boycott laws, special sanctions

Kara Bombach assists companies in numerous industries to lawfully export goods, technology and services around the globe. Her international trade practice focuses on compliance with 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. Ms. Bombach regularly represents clients in foreign trade-related matters before U.S. government agencies, including the Departments of Commerce, State, Treasury and Defense. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations.

National and multi-national companies (including Fortune® 5) have engaged Kara to assist in establishing and maintaining effective trade compliance programs critical to efficient and productive international business operations. Among other things, she regularly counsels clients in designing and implementing global anti-corruption and trade compliance programs, including complex and high impact issues such as compliance assessments and government investigations. She has significant experience advising clients on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anticorruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

Yosbel Ibarra, Greenberg Traurig, complex business transactions attorney, public-private partnership counsel, mergers acquisitions lawyer, joint ventures law, private equity litigator, international legal representation
Shareholder; Co-Chair, Latin American and Iberian Practice

Yosbel A. Ibarra advises clients on complex business transactions in the United States, Spain and across Latin America. Fluent in Spanish, he has wide-ranging experience in cross-border M&A, debt finance and project finance transactions, including public-private partnerships. Yosbel also serves as Co-Hiring Shareholder for the Miami office.

Areas of Concentration

  • Mergers and acquisitions
  • Cross-border financing transactions
  • Project financing
  • ...
Carl A. Fornaris, Financial Attorney, Greenberg Traurig, non-U.S. loan counsel, FINRA lawyer, financing transaction law
Shareholder; Co-Chair, Financial Regulatory and Compliance Practice

Carl A. Fornaris is Co-Chair of the firm's Financial Regulatory and Compliance Practice. With more than 20 years of legal experience, Carl concentrates his practice on the representation of financial services firms in all aspects of their business. In particular, he represents U.S. and non-U.S. firms on finance and corporate matters, and provides supervisory and compliance counseling for institutions regulated by the Federal Reserve, OCC, FDIC, FinCEN, CFPB, SEC, FINRA, Florida Office of Financial Regulation and other state supervisory authorities.