It is often hard to gauge the efficacy of the sanctions regulations administered by the United States Department of Treasury Office of Foreign Assets Control (“OFAC”). However, I recently came across an article written by an obvious opponent of U.S. sanctions against Cuba and it had some interesting–although outdated–statistics.

According to the article:

“Adults lost 20-40 pounds during the 1990s. Shortages accounted for increased death rates and difficulties treating and preventing specific illnesses. The 1997 study, “Impact of the U.S. Embargo on the health and Nutrition in Cuba,” produced by the American Association of World Health, provided clear documentation.

The CDA added an estimated 30 percent cost to Cuban imports of “essential goods.” (See Levy and Sidel, “War and Public Health,” 2000.) Cuba had to pay extra to third parties to secure off-limits medical supplies. Only small and distant suppliers remained.”

The article also goes on to discuss the disproportionate fines leveled against those you violated the Cuban Assets Controls Regulations, a fact that has been highlighted previously on this blog as well as by others.

OFAC has seemed to have lightened up on Cuba since Obama has taken office, however, that should not be taken as a sign that the sanctions no longer apply. They are still very much in effect, OFAC is still enforcing them, and if the article noted above is any indicator, they are still effective.

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 or

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