On January 15, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control, released revised Cuban Assets Control Regulations to implement policy changes announced by President Obama on December 17, 2014. The revised regulations, effective January 16, 2015, make relatively modest changes to the existing U.S. sanctions against Cuba.
Among other revisions, the new regulations relax restrictions on existing categories of authorized travel to Cuba and permit certain transactions by authorized travelers. The revised regulations also modestly ease restrictions on financial transactions with Cuban persons outside Cuba and permit banks to reject, rather than block, most funds transfers in which a Cuban person has an interest; however, the revised regulations generally do not authorize transactions directly with or investment in Cuba. In addition, as the alert memo discusses in greater detail, there is some doubt as to whether the relief provided fully applies to U.S. dollar clearing operations conducted by the U.S. branches of foreign banks.
To learn more about the revisions to the Cuban Asset Control Regulations and the potential omission of U.S. branches to foreign banks, please click below to read our full alert memo.
If you have any questions, please feel free to contact any of your regular contacts at the Firm, or Paul Marquardt of our Washington office.
