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Revised Cuban Sanctions Regulations


On January 16, 2015 the US Office Of Foreign Asset Control (OFAC) announced amendments to the Cuban Asset Control Regulations.

The relaxation measures include:

  • non-US vessels being authorised to enter the US after engaging in certain licensed trade with Cuba.  The trade in respect of which this measure applies is limited, but includes exports to Cuba from a third country of agricultural commodities, medicine or medical devices, and carrying students;
  • authorisation of import into the US of goods and services provided by “independent Cuban entrepreneurs”;
  • authorisation of certain exports from the US to non-governmental entities in Cuba;

Previously, travel to Cuba by US persons was permitted in 12 categories of authorized travel, but only subject to specific licenses, which were determined on a case by case basis after an application. OFAC has now issued general licenses for travel to Cuba related to the following activities:
 Family visits
 Official business of the U.S. Government, foreign governments and certain intergovernmental organizations
 Journalistic activity
 Professional research and professional meetings
 Educational activities
 Religious activities
 Public performances, clinics, workshops, athletic and other competitions, and exhibitions
 Support for the Cuban people
 Humanitarian projects
 Activities of private foundations or research or educational institutes
 Exportation, importation or transmission of information or information materials
 Certain expert transactions

All insurance related activities which are necessary and incidental to the performance of licensed passenger transportation to Cuba will fall under the umbrella of the license, including insurance and insurance brokerage services provided by  US based brokers, insurers or reinsurers. 

Most transactions between U.S. persons and Cuba continue to be prohibited, and save for certain limited transactions, US banks cannot engage in financial transactions involving Cuba.