With simultaneous FINAL RULES scheduled to be published in tomorrow’s (June 5th, 2019) Federal Register, both OFAC and BIS will, effective tomorrow, be rescinding liberalization of travel rules that were enacted in the waning days of the Obama Administration. Specifically, with regard to BIS, tomorrow’s final rule amends license exception AVS (temporary sojourn of aircraft, vessels and spacecraft) effectively removing use of this license exception for passenger and recreational vessels from making temporary sojourn to Cuba. Under the new rule, AWS will no longer apply for cruise lines (and many aircraft as well) and BIS licenses for cruises will be subject to a presumption of denial (sorry, looks like no more Cuba cruises!). Air travel will face restrictions with some exceptions. In a separate final rule to be published tomorrow (June 5th 2019) OFAC is amending § 515.565 of the Cuban Assets Control Regulations (31 CFR Part 515) to remove the authorization for group people-to-people educational travel in § 515.565(b). OFAC is adding a “grandfathering” provision in § 515.565(b) to authorize certain group people-to-people educational travel that previously was authorized where the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to June 5th, 2019. If you want to take advantage of the group people-to-people educational travel exception better book before midnight today as it will be too late tomorrow. The Trump Administration is citing Cuba’s support for anti-democratic regimes, namely Venezuela for this new tightening of regulations. The Administration is intent on limiting the export of hard currency to Cuba, and effectively ending what was a short lived détente between the U.S. and Cuba. For more details on changes to the Cuban regulations please contact our office.
Terms of Service/Disclaimer: The materials and information contained on this site are provided for informational purposes only and are not to be considered as legal or regulatory advice. Transmission of the information is not intended to create, and receipt does not constitute, a consultancy-client relationship between the sender and receiver. Jonathan Fink and TSI Global Consulting, LLC do not provide any warranties whatsoever with respect to any materials or hyperlinks found throughout this web site. These materials and hyperlinks are offered as a service to our readers. All information, including hyperlinks, on this site is presented “as is” and without any warranties that the information is useful, accurate or true, and all liability arising from use of this site is hereby disclaimed. Visitors to this web site should not act upon any information found on this web site without first seeking professional legal and/or regulatory export compliance counsel. Views expressed by readers in comments to blog posts are views of those readers alone and are not the views of TSI Global Consulting, LLC. Readers leaving comments grant to TSI Global Consulting LLC all intellectual property rights in such comments, including the right to edit or modify such comments. Comments may be edited or deleted for any reason at the sole option of TSI Global Consulting, LLC