Cuba

Information as of: 16th October 2019

Further Details
UN
US On 9th Sept 2019 31 C.F.R. part 515 amended CACR to implement further restrictions on US banks.
EU/UK
Financial/Other Sanctions
UN No
US EO 1285431 C.F.R. part 515
EU/UK No
Arms Embargo
UN No
US Yes, 49 FR 47682
EU/UK No
Further Details
UN No
US Longstanding policy objective to isolate the Cuban government economically & deprive it of USD. Stringent import & export rules apply, although there was a relaxation of certain measures in Sep 2009. A licensing system applies for those engaging in travel-related services (list of authorised air travel providers & forwarding services updated periodically & practices updated Jul 2012) & for certain electronic communication providers (Mar 2010)). Effective 29 May 2015, Cuba was removed from the US list of state sponsors of terrorism. A number of vessels removed from SDN list June 2015. 15 Jan 2015 saw the further easing of some travel restrictions and telecoms exports (31 CFR Part 151). WEF 21 Sep 2015 certain restrictions lifted in respect of travel, financial transactions and doing business in the country. OFAC updated FAQ page regarding the provision of Cuba-related insurance Dec 2015 and in relation to USD transactions in Apr 2016 and Jul 2016. The latter made an important clarification on the 'U-turn' general license. 27 Jan 2016 restrictions lifted in respect of certain payment and financing restrictions for authorised exports, certain restrictions on Cuban Airlines lifted and some transactions authorised. 16 Mar 2016 further restrictions lifted in respect of travel, financial transactions and doing business in the country. 8 US airlines have been granted permission by the US Department of Transportation (DOT) to begin scheduled flights between the US and Cuba effective 31 Aug 2016. Wef: 17th October 2016; 31 CFR Part 515 amends the Cuban Assets Control Regulations (CACR) to include changes to safety-related services for Civil Aviation, allows certain vessel transactions and generally authorises air cargo to transit Cuba. Wef: 9th November, CACR amended to include restrictions on direct financial transactions with firms related to the Cuban military, intelligence, and security services. WEF 17th April 2019 Title III of the Helms-Burton Act waiver was lifted which had prevented claims against foreign companies operating in Cuba being brought by former owners of property expropriated by the Cuban government. As at 5th Jun 2019 travel restriction were enforced on group trips, recreational vessels and aircraft to Cuba under the Cuban Asset Control Regulation (CACR). SDN list updated periodically. On the 19 Feb 2019 the national emergency declared in Proclamations 6867, 7757, 9398, and 9699 was extended for a year. On 9th Sept 2019 31 C.F.R. part 515 amended CACR to implement further restrictions on US banks.
EU/UK No
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.