Last week, over five decades of U.S. sanctions policy came crashing down with the announcement that the Obama administration would begin an effort to relax the Cuban embargo and normalize relations with our communist neighbor to the south. The first step in this process was the release of former USAID contractor Alan Gross, who had been held in Cuba for the past 5 years after being arrested for providing satellite phones and computer equipment to the Cuban Jewish community. At the same time, 3 remaining members of the“Cuban Five” were released in exchange for a U.S. intelligence asset who had been imprisoned in Cuba for the past 20 years.

It has long been rumored that the administration and particular members of the Treasury Department were in favor of further relaxing the Cuba embargo, however, there were few if any warning signs that this would happen in the immediate future.

According to a Fact Sheet released by the White House, the U.S. will soon make the necessary changes to the Cuban Assets Control Regulations (“CACR”) and the Export Administration Regulations (“EAR”) to allow a far broader range of economic activity. As has been the case with some past cases of sanctions relaxation (see Burma, Zimbabwe), in most cases prohibitions contained in the regulations will not be removed; rather general licenses will be issued covering activity that previously required specific licensing.

The change most relevant to the broader public is most likely the switch from a specific to a general licensing regime for Cuba travel. Under the new rules, the twelve existing categories of Cuba-related travel that currently require a specific license will be generally licensed. Travelers will still be required to make reservations using a Travel Service Provider (TSP), however any business wishing to facilitate Cuba travel will be generally licensed to do so, as long as they follow the regulations of the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). But those who are already planning their next Cuban vacation should probably wait–tourism still does not qualify as one of the approved categories.

The good news is, if you do decide to take advantage of the new travel general licenses, you are in luck. That is because licensed U.S. travelers are now authorized to come home with up to $400 worth of goods from Cuba, including up to $100 in tobacco products and alcohol. Fans of Cohibas and Cuban rum rejoice! You can even purchase these products using your debit or credit card, which will now be authorized for use in Cuba.

The announced changes also attempt to bring the Cuba sanctions in line with other sanctions regimes administered by Treasury. The Cuba embargo is different from every other U.S. sanctions program in that it is imposed pursuant to the Trading with the Enemy Act of 1917 (TWEA) rather than the International Emergency Economic Powers Act (IEEPA). A key characteristic of the TWEA is that all Cuban nationals are considered blocked persons—therefore U.S. companies are prohibited from dealing with Cuban individuals wherever they are. This has led to unfortunate scenarios where, for example, a U.S. hotel chain has refused service to Cuban delegations, despite the fact that EU law renders complying with the U.S. Cuba embargo illegal.

Under the proposed change, U.S. owned or controlled entities will be authorized to provide services to Cuban individuals in third countries. Additionally, Cuban nationals who have relocated outside of Cuba will be allowed to open accounts with U.S. banks.

Another major revision is that U.S. financial institutions will now be allowed to open correspondent accounts at Cuban financial institutions to facilitate the processing of authorized transactions. The inability to conduct the financial transactions ordinarily incident to licensed activity has long been identified as a significant weakness in U.S. sanctions regimes, including Cuba, Iran, and Sudan. Hopefully this will result in a greater volume of authorized transactions between the two countries taking place.

These are only a few of the changes announced by the White House and as with any modification in U.S. sanctions, the devil is in the details. While the announcement by the White House is an interesting summary, the true extent of the sanctions relaxation will not be known until Treasury and Commerce produce updated versions of the CACR and EAR. According to a new FAQ, OFAC intends to publish new regulatory amendments “in the coming weeks.”

Now you may be asking yourself “Wait a second! I thought that the Cuba embargo is codified pursuant to §102(h) of the Cuban Liberty and Democracy Solidarity Act of 1996 (known primarily as the Helms-Burton Act)? How is the President going to accomplish such a significant revision to the sanctions architecture?” Good question. Thankfully, our friends over at Hogan Lovells published an in-depth analysis on just that question back in 2011. The extent of presidential authority over ostensibly congressional sanctions is instructive as the U.S. considers its options for relaxing Iran sanctions in the event of a nuclear deal.

Though expectations are currently running high, it is worthwhile to consider the Burma example before declaring open season on investment in Cuba. Though sanctions have be significantly eased over the past two and a half years, many U.S. companies remain extremely hesitant to do business in Burma due to remaining compliance issues. In addition, U.S. depository institutions have not rushed back into Burma or even opened correspondent banking relationships with Burmese banks despite their ability to do so in certain circumstances.

A number of members of Congress have also voiced their displeasure at the proposed relaxation of the Cuba embargo. Many of these members are also very familiar with OFAC and have not been shy about putting pressure on the agency over enforcement (see 99 Problems but OFAC Ain’t One). There will likely be a great deal of Congressional pressure on OFAC to continue enforcing remaining sanctions, which U.S. companies in particular must consider before deciding to plunge into Cuba.

In all, the Cuba embargo is an antiquated relic of the Cold War based on a piece of legislation that is a relic of World War I. The policy had few defenders among those responsible for both administering and complying with sanctions. Hopefully this is only the first step that will eventually result in improved relations, as well as a better life for the Cuban people.