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January 26, 2015
U.S. Economic Sanctions
United States Eases Elements of Cuban Embargo; New Regulations
Issued by U.S. Treasury and Commerce Departments Implement
Cuban Policy Changes Announced in December
SUMMARY
Effective January 16, 2015, the United States Department of Treasury’s Office of Foreign Assets Control
(“OFAC”) and the United States Department of Commerce’s Bureau of Industry and Security (“BIS”)
issued regulations revising the Cuban Assets Control Regulations (“CACR”) and the Export
Administration Regulations (“EAR”), respectively, in order to implement U.S. policy changes towards
Cuba announced by the Obama Administration on December 17, 2014.
The changes are targeted to further engage and empower the Cuban people. Although these regulations
have eased certain elements of the Cuban embargo, particularly in the areas of travel,
telecommunications, remittances, certain financial services and support for the Cuban people, the
changes are incremental and the Cuban embargo, which also has been codified into law by various
statutes enacted since the embargo was first adopted, remains in place.1 Transactions between the
United States, or persons subject to U.S. jurisdiction, and Cuba generally remain prohibited unless
authorized or exempt.2
The changes are very detailed and technical, and despite the Obama
Administration’s new policy towards Cuba, care must be taken to ensure that any activity undertaken in
reliance on the new authorizations strictly conforms to the terms and conditions of the regulations. The
changes are summarized below.
OFAC’S AMENDMENTS TO THE CACR
Procedurally, OFAC’s amendments to the CACR generally consist of OFAC: issuing new “general
licenses,” generally authorizing transactions that would otherwise be prohibited by the CACR; changing
certain matters previously eligible for a “specific license”—which require the licensee to obtain permission
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from OFAC to engage in otherwise prohibited acts on a case by case basis—into general licenses; and
expanding existing general licenses to authorize a broader array of activity.
Concurrently with the
issuance of the revised CACR, OFAC published a set of Frequently Asked Questions (“FAQs”) providing
additional guidance.3
Travel to Cuba and Travel Services, Including Insurance
Travel for tourist activities continues to be prohibited, but the changes ease the regulatory burden
associated with permissible travel to Cuba. OFAC amended the CACR to generally license certain types
of travel to, from or within Cuba which previously could be conducted only after the issuance of a specific
license by OFAC; with the amendments, there are 12 generally licensed categories of travel to Cuba.4
The CACR provide that persons engaged in authorized travel to Cuba may engage in enumerated “travelrelated transactions,” such as transportation-related transactions incident to travel to and from Cuba, the
payment of living expenses in Cuba, and the acquisition in Cuba of goods for personal consumption,
among other things. OFAC’s revisions to the CACR remove per-diem caps on living expenses while in
Cuba, allow authorized travelers to Cuba to return to the United States with up to $400 worth of
merchandise for personal use only (provided, among other things, that no more than $100 of the
merchandise consists of alcohol or tobacco products), and raise the value of remittances that authorized
travelers are allowed to carry to Cuba from $3,000 to $10,000.5
As discussed below, OFAC’s
amendments to the CACR enable authorized travelers to use U.S. credit and debit cards in Cuba for
authorized expenses, and U.S. financial institutions are permitted to enroll merchants to process those
transactions, but there is no requirement that U.S. financial institutions process such transactions.6
OFAC also amended the CACR to generally authorize any person subject to U.S. jurisdiction, including
travel agents and tour group operators and airlines, to provide travel and carrier services in connection
with authorized travel involving Cuba,7 subject to recordkeeping and reporting requirements.8
The
provision of these services previously required a specific license from OFAC. The CACR also authorize
the provision of health, life and travel insurance-related services to authorized travelers to Cuba, as well
as the receipt of emergency medical services and the making of payments related thereto.9 In addition,
OFAC added a general license authorizing persons subject to U.S. jurisdiction to issue or provide
coverage for global health, life or travel insurance policies for individuals ordinarily resident in a country
outside of Cuba who travel to or within Cuba, which permits persons subject to U.S. jurisdiction to service
those policies, and pay claims arising from events that occur, while the individual is or was traveling in, to
or from Cuba.10
The CACR, as revised, also generally authorize all transactions incident to the
processing and payment of credit cards, debit cards, stored value cards, checks, drafts, travelers’ checks,
and similar instruments used or negotiated in Cuba by any person authorized by the CACR to engage in
financial transactions in Cuba.11 Previously, transactions incident to processing credit and debit card
transactions in Cuba were not authorized. OFAC also amended this general license to permit persons
subject to U.S. jurisdiction that process such transactions to rely on the traveler in determining whether
-2U.S. Economic Sanctions
January 26, 2015
the underlying transaction is authorized, so long as persons processing the transaction do not know or
have reason to know that the transaction is not authorized.12 In reliance on the new licenses, MasterCard
announced that it is removing the current block on U.S.-issued card transactions in Cuba as of March 1,
2015.13
Remittances
OFAC amended the CACR to raise the limits on certain remittances to Cuban nationals14 and to generally
authorize additional types of remittances. Specifically, OFAC raised the limits on generally licensed
periodic remittances from persons subject to the jurisdiction of the United States to Cuban nationals from
$500 to $2,000 per quarter.15 Remittances to certain officials of the Cuban Government or members of
the Cuban Communist Party remain prohibited.16 In addition, OFAC generally authorized remittances in
unlimited amounts from persons subject to U.S. jurisdiction to individuals and independent nongovernment entities in Cuba for the following purposes: (i) to support humanitarian projects in or related
to Cuba that are designed to directly benefit the Cuban people; (ii) to support the Cuban people through
activities of recognized human rights organizations, independent organizations designed to promote a
rapid, peaceful transition to democracy, and activities of individuals and non-governmental organizations
that promote independent activity intended to strengthen civil society in Cuba; and (iii) to support the
development of private businesses, including small farms.17
OFAC also expanded the types of entities generally authorized to process authorized remittances to
Cuba without first obtaining a specific license from OFAC to include all “banking institutions”, which OFAC
clarified includes U.S. registered money transmitters and U.S. registered brokers or dealers in
securities.18 Previously, only depository institutions19 were generally authorized to process authorized
remittances. The general authorization is subject to certain recordkeeping and reporting requirements.20
Banking
The recent amendments to the CACR add general authorizations for various financial transactions. U.S.
depository institutions are now permitted to establish and maintain correspondent accounts at financial
institutions in Cuba, provided that the accounts are used only for transactions authorized under the
CACR.21 This general license does not, however, permit the establishment or maintenance of accounts
in the United States or with a person subject to U.S. jurisdiction by, on behalf of, or for the benefit of,
Cuba or a Cuban national.22 Additionally, U.S. depository institutions are permitted to set up testing
arrangements and exchange authentication keys with Cuban financial institutions for conducting
transactions authorized by the CACR.23 All transactions incident to the processing and payment of credit
and debit cards involving travel-related and other transactions in Cuba also are authorized.24
OFAC also implemented changes that affect how U.S. depository institutions treat wire transfers involving
Cuba or a Cuban national. Previously, U.S. depository institutions were required to block all payments in
which Cuba or a Cuban national had an interest, to the extent such payments were not otherwise
-3U.S. Economic Sanctions
January 26, 2015
authorized by or exempt from the CACR. OFAC has issued a new general license authorizing U.S.
depository institutions to reject, instead of block, funds transfers that originate and terminate outside of
the United States, provided that neither the originator nor the beneficiary is a person subject to U.S.
jurisdiction and provided that prohibited officials of the Cuban Government or prohibited members of the
Cuban Communist Party do not have an interest in the transfer.25 The general license also authorizes
U.S. depository institutions to process funds transfers in which Cuba or a Cuban national have an interest
that originate and terminate outside the United States, provided that neither the originator nor the
beneficiary is a person subject to U.S. jurisdiction and provided that the funds transfer would be
authorized under the CACR if the originator or beneficiary were a person subject to U.S. jurisdiction.26
Telecommunications
The OFAC amendments expanded the scope of a general license of the CACR, so that transactions
(including payments) incident to the establishment of facilities (including fiber-optic cable and satellite
facilities) to provide telecommunications services27 linking the United States or third countries and Cuba,
including facilities to provide telecommunications services in Cuba, are authorized.28
OFAC also
updated general licenses authorizing telecommunications-related transactions, including payment related
to the provision of telecommunications, involving Cuba or provided to Cuban individuals, provided such
individuals are not prohibited officials of the Government of Cuba or prohibited members of the Cuban
Communist Party. Under these authorities, U.S. persons may, for example, purchase calling cards for
people to use in Cuba or pay directly to a telecommunications operator located in Cuba.29 In addition,
OFAC expanded a general license to authorize persons subject to U.S. jurisdiction to provide additional
services to Cuba incident to internet-based communications (such as instant messaging, social
networking, web browsing and blogging), as well as services related to exportation and reexportation of
certain communications items.30
Transactions with Cuban Nationals Outside of Cuba
OFAC’s amendments to the CACR authorize U.S. owned or controlled entities organized or operating in
third countries to provide goods and services (including financial services) to Cuban nationals located
outside of Cuba, provided, among other things, that the transaction does not involve a commercial
exportation of goods or services to or from Cuba.31 U.S. owned or controlled entities are not permitted
under this license to export to Cuba commodities produced in the authorized trade territory, nor to
reexport to Cuba items of U.S. origin. Such persons also continue to be prohibited from engaging in
transactions with respect to Cuban-origin goods.
In addition, OFAC amended the CACR to generally authorize individual Cuban nationals that have taken
up permanent residence outside of Cuba to be treated as unblocked nationals, meaning that the
prohibitions of the CACR generally do not apply to such individuals.32 OFAC also issued a new general
license allowing persons subject to U.S. jurisdiction to sponsor, provide services in connection with, and
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January 26, 2015
participate in conferences or other similar events in a third country that are attended by Cuban nationals,
provided the event does not relate to tourism in Cuba.33
Imports of Products of Cuban Entrepreneurs
OFAC issued a new general license authorizing persons subject to U.S. jurisdiction to engage in all
transactions, including payments, necessary to import goods and services produced by independent
Cuban entrepreneurs as determined by the State Department, to be set forth by the State Department at:
http://www.state.gov/e/eb/tfs/spi/.34 To date, the State Department has not published this list.
Diplomatic Activity and International Organizations
OFAC broadened a general license allowing U.S. depository institutions to process funds transfers for the
official business of third country diplomatic or consular missions in Cuba to also authorize the processing
of funds transfers for the official business of international intergovernmental organizations in which the
United States is a member or holds observer status.35 The license was also expanded to allow U.S.
depository institutions to process funds transfers and maintain accounts for the personal expenditures of
employees, grantees and contractors, as well as persons who share a common dwelling as a family
member of such persons, of third country diplomatic mission or intergovernmental organizations in
Cuba.36 Finally, to facilitate the reestablishment of diplomatic relations with Cuba, OFAC issued a new
general license authorizing the provision of goods and services in the United States to official missions of
the Government of Cuba to the United States and to international organizations in the United States, and
payment for such goods and services, subject to conditions, including that the goods and services are for
the conduct of official business.37
BIS’S AMENDMENTS TO THE EAR
BIS administers the Export Administration Regulations controlling the transfer of U.S.-origin “dual-use”
goods and services (i.e., goods or services that have both civilian purposes and potential military
applications). The new BIS regulations modify U.S. export policy towards Cuba, and generally
complement OFAC’s revisions. Similar to OFAC, BIS implemented its changes by creating new
authorizations, or expanding existing authorizations, that provide for exceptions to the licensing
requirements of the EAR.38
Private Sector Tools and Equipment: BIS introduced a new License Exception SCP (“Support for the
Cuban People”), which authorizes the export and reexport of certain commercially sold or donated items
which fall within one or more of the following categories: (i) building materials, equipment and tools for
use by the private sector to construct or renovate privately owned buildings; (ii) tools and equipment for
private sector agricultural activity; and (iii) tools, equipment, supplies, and instruments for use by private
sector entrepreneurs (e.g., auto mechanics, barbers, hairstylists and restauranteurs).39 Items eligible for
export and reexport to Cuba pursuant to this aspect of License Exception SCP are only those designated
-5U.S. Economic Sanctions
January 26, 2015
EAR99 (i.e., items subject to the EAR but not specified in any Export Control Classification Number) or
controlled on the Commerce Control List only for anti-terrorism reasons.
Donated Items for Specified Purposes: License Exception SCP also authorizes the export and reexport
to Cuba of certain donated items for use in scientific, archaeological, cultural, ecological, educational,
historic preservation or sporting activities40 as well as the temporary export to Cuba of certain items by
persons departing the United States for their use in connection with such purposes or for their use in
professional research (directly related to the traveler’s profession, professional background or area of
expertise) so long as they are returned to the United States within two years, unless consumed in Cuba
or otherwise authorized by a license from BIS.41
These rules exclude items on the United States
Munitions List (22 C.F.R. Part 121) or Commerce Control List (Supplement 1 to Part 774 of EAR), unless
the only reason for control of the item on the CCL is for anti-terrorism reasons.
Human Rights Organizations: License Exception SCP authorizes the export and reexport to Cuba of
certain items to human rights organizations, individuals, or non-governmental organizations that promote
independent activity intended to strengthen civil society. Similar to the aspect of License Exception SCP
regarding private sector tools, items eligible for export and reexport to Cuba pursuant to this aspect of
License Exception SCP are only those designated EAR99 or controlled on the Commerce Control List
only for anti-terrorism reasons.
Telecommunications Items: License Exception SCP authorizes the export and reexport of certain items
for telecommunications (including access to and the use of the Internet) and use by news media
personnel and U.S. news bureaus engaged in the gathering and dissemination of news to the general
public.42 Only items designated EAR99 or controlled on the Commerce Control List only for anti-terrorism
reasons are eligible.
Consumer Communications Devices: The existing License Exception for Consumer Communications
Devices, created in 2009, authorized the export or reexport of certain communications commodities and
software (such as recording devices, mobile phones and computers) that are donated by the exporter or
reexporter to an eligible end user free of charge. BIS amended this licensing exception by eliminating the
donation requirement in the rule,43 thereby authorizing the export and reexport of eligible commercially
sold communications commodities and software to eligible end users in Cuba.
Gift Parcels and Humanitarian Donations: License Exception GFT, for gifts and humanitarian
donations, was amended to authorize exports of multiple gift parcels exported in a single shipment for
delivery to individuals residing in a foreign country, including but not limited to Cuba. This eliminates the
need to obtain individual licenses for each gift parcel in the shipment.44
Environmental Protection: BIS also added a provision to the EAR establishing a general policy of
approval for exports and reexports to Cuba of items necessary for the environmental protection or
-6U.S. Economic Sanctions
January 26, 2015
enhancement of U.S. and international air quality, water quality or coastlines.45 This includes items
related to renewable energy or energy efficiency.
NEXT STEPS
As noted by Secretary of the Treasury Jacob Lew, the amendments issued by BIS and OFAC are meant
to put in place a policy that helps promote political and economic freedom for the Cuban people such that
they do not need to rely on the Cuban state.46 Although significant, the changes represent an incremental
easing, and not the lifting of, Cuban Sanctions, and “OFAC continues to enforce the prohibitions of the
CACR.”47
There are likely to be compliance challenges occasioned by the revisions to the CACR, especially for
U.S. financial institutions attempting to determine whether a transaction underlying a funds transfer is
authorized under the expanded general licensing regime of the CACR, and there may be additional
guidance or clarification as those challenges begin to surface. Clients interested in further information
concerning the recent amendments to the CACR and EAR should contact the Sullivan & Cromwell
lawyers identified at the end of this memorandum.
*
*
Copyright © Sullivan & Cromwell LLP 2015
-7U.S. Economic Sanctions
January 26, 2015
*
ENDNOTES
1
The Helms-Burton Act, which among other things, provides the possibility of a private right of
action against persons who “traffic” in confiscated property, remains in effect.
2
Persons subject to the jurisdiction of the United States include (i) any individual, wherever
located, who is a citizen or resident of the United States; (ii) any person in the United States;
(iii) any corporation, partnership, association or other organization organized under the laws of
the United States or of any State, territory, possession, or district of the United States; and
(iv) any corporation, partnership, association or other organization, wherever organized or doing
business, which is owned or controlled by any person or persons specified in (i) through (iii).
Thus, foreign subsidiaries of U.S.-organized entities are generally subject to the prohibitions of
the CACR.
3
See OFAC, “Frequently Asked Questions Related to Cuba,” (Jan. 15, 2015), available at:
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf.
4
31 C.F.R. § 515.560. The categories of travel for which a general authorization, subject to
conditions and limitations, is now available include: (i) family visits; (ii) official business of the
U.S. government, foreign governments, and certain intergovernmental organizations;
(iii) journalistic activity; (iv) professional research and professional meetings; (v) educational
activities; (vi) religious activities; (vii) public performances, clinics, workshops, athletic and other
competitions, and exhibitions; (viii) support for the Cuban people; (ix) humanitarian projects;
(x) activities of private foundations or research or educational institutes; (xi) travel related to the
exportation, importation or transmission of information or informational materials; and (xii) travel
related to certain authorized exportations with respect to U.S. owned or controlled foreign firms.
OFAC’s FAQs provide substantial guidance regarding the type of activities that are authorized
under each category of travel to, from or within Cuba. See FAQs, § II, “Travel”.
5
31 C.F.R. §§ 515.560(c)(2)-(4). See also FAQs 21-23, 28.
6
31 C.F.R. § 515.584.
7
31 C.F.R. § 515.572.
8
Note 1 to § 515.560. See §§ 501.601 and 501.602 for recordkeeping and reporting requirements.
See also FAQ 26.
9
Note 2 to 31 C.F.R. § 515.560.
10
31 C.F.R. § 515.580.
11
31 C.F.R. § 515.560(c)(5).
12
Id.
13
The
announcement
appears
on
MasterCard’s
website
at:
http://newsroom.mastercard.com/news-briefs/mastercard-removes-block-on-cuba-transactionsfor-u-s-issued-cards/.
14
A Cuban national includes: (i) a subject or citizen of Cuba or any person who has been domiciled
in or a permanent resident of Cuba at any time on or since July 8, 1963, except persons who
were permanent residents of or domiciled in Cuba in the service of the U.S. Government and
persons whose transactions in that country were authorized by OFAC; (ii) any partnership,
association, corporation, or other organization that, on or since the effective date: (a) was or has
been organized under the laws of Cuba; (b) had or has had its principal place of business in
Cuba; or (c) was or has been controlled by, or a substantial part of the stocks, share, bonds,
debentures, notes, drafts, or other securities or obligations of which was or has been controlled
by, directly or indirectly, Cuba and/or one or more nationals thereof; (iii) any organization’s office
or other sub-unit that is located within Cuba; (iv) any person to the extent that such person, on or
since July 8, 1963 was or has been acting or purporting to act directly or indirectly for the benefit
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U.S. Economic Sanctions
January 26, 2015
ENDNOTES (CONTINUED)
or on behalf of any national of Cuba; and (v) any other person who there is reasonable cause to
believe is a “national.”
15
31 C.F.R. § 515.570(b). See FAQ 28.
16
31 C.F.R. § 515.570(b)(3). See FAQ 28.
17
31 C.F.R. § 515.570(g). See FAQ 28.
18
31 C.F.R. § 515.572(a)(3). See FAQ 29. The term “banking institutions” includes any person
engaged primarily or incidentally in the business of banking, of granting or transferring credits, or
of purchasing or selling foreign exchange or procuring purchases and sellers thereof, as principal
or agent, or any person holding credits for others as a direct or incidental part of his business, or
any broker. 31 C.F.R. § 515.314.
19
The term depository institution means any of the following: (i) an insured bank as defined in
section 3 of the Federal Deposit Insurance Act; (ii) an insured institution as defined in section
408(a) of the National Housing Act; (iii) an insured credit union as defined in section 101 of the
Federal Credit Union Act; or (iv) any other institution that is carrying on banking activities
pursuant to a charter from a Federal or state banking authority. 31 C.F.R. § 515.533.
20
31 C.F.R. § 515.572(b).
21
31 C.F.R. § 515.584(a). See FAQs 32-33.
22
See FAQ 33.
23
31 C.F.R. §§ 515.584(b).
24
31 C.F.R. § 515.584 (c). See FAQ 30-31.
25
31 C.F.R. § 515.584(d)(1). See FAQ 36.
26
See 31 C.F.R. § 515.584(d)(2). See FAQ 36.
27
The term “telecommunication services” includes “data, telephone, telegraph, internet connectivity,
radio, television, news wire feeds, and similar services, regardless of the medium of transmission,
including transmissions by satellite.” 31 C.F.R. § 515.542(f).
28
31 C.F.R. § 515.542(d). See FAQ 41.
29
31 C.F.R. § 515.542(c). See FAQ 41.
30
31 C.F.R. § 515.578. See FAQ 41.
31
31 C.F.R. § 515.585. See FAQs 43-44
32
In determining whether an individual Cuban national qualifies as unblocked under this
authorization, persons subject to U.S. jurisdiction must obtain evidence that such individual has
taken up permanent residence outside of Cuba. See 31 C.F.R. § 515.505; FAQs 35 and 42. See
also 31 C.F.R. § 515.307.
33
31 C.F.R. § 515.581.
34
31 C.F.R. § 515.582.
35
31 C.F.R. § 515.579(a).
36
31 C.F.R. § 515.579(b).
37
31 C.F.R. § 515.586.
38
Generally, all items that are subject to the EAR (most goods and technology subject to U.S.
jurisdiction, with limited exceptions) require a license for export or reexport to Cuba unless
authorized by a license exception.
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U.S. Economic Sanctions
January 26, 2015
ENDNOTES (CONTINUED)
39
15 C.F.R. § 740.21(b).
40
15 C.F.R. § 740.21(c)(1).
41
15 C.F.R. § 740.21(c)(2).
42
15 C.F.R. § 740.21(d).
43
15 C.F.R. § 740.19.
44
15 C.F.R. § 740.12.
45
15 C.F.R. § 746.2(b)(6).
46
See Department of Treasury, “Statement by Secretary Lew on Amendments to the Cuban Assets
Control Regulations,” (Jan. 1, 2015).
47
OFAC, “Frequently Asked Questions Related to Cuba,” (Jan. 15, 2015), available at:
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf.
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January 26, 2015
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SC1:3781905.6