On Thursday November 9th, the Office of Foreign Assets Control (“OFAC”) published new regulations in the Federal Register executing June’s National Security Presidential Memorandum (“NSPM”) regarding U.S. sanctions against Cuba. (See our previous post on the NSPM here). The State Department and Bureau of Industry and Security (“BIS”) also published complementary rules giving effect to the changes in the Cuba sanctions. The rules became effective with their publication in the Federal Register.
The primary purpose of the rule changes is to prevent commerce between the U.S. and Cuba from benefiting the Cuban military. The State Department’s regulation includes a new Cuba Restricted List, which lists parties deemed to be under control of or acting on behalf of the Cuban military, intelligence, or security services personnel.