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It feels like it’s becoming a monthly occurrence, but the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) has updated their list of Cuba Service Providers. These service providers are authorized to provide travel services to and from Cuba, as well as remittance services, to those U.S. persons holding a specific license authorization from OFAC.

The Cuba Sanctions program, known as the Cuban Assets Control Regulations (“CACR”), is an interesting one because there are very defined categories for which one can obtain a specific license for travel to Cuba. Amongst those categories are travel to participate in sporting and cultural events, travel for journalistic activities, and travel for religious purposes. In addition to these categories, there is an authorization in place allowing U.S. persons with close relatives in Cuba to travel to Cuba to visit those individuals. A close relative is defined as being related to the U.S. person within three generations. Therefore, it does not just include parents, children, and brothers and sisters; it is much more broad.

Undoubtedly, we will see another update of this list soon. The increasing number of authorized service providers indicates the easing of enforcement of the CACR. However, that should not lead one to believe that they can travel freely to Cuba. If one does not have a close relative there, then they must apply for a specific license. As mentioned previously, to obtain a specific license an individual will have to fall into a certain category. To determine whether one falls into a certain category, contact an attorney who is experienced in dealing with the CACR and with OFAC.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.

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