Trump’s 243 measures against Cuba

Compendium of Trump’s measures against Cuba

Translated and edited by Walter Lippmann for CubaNews.
Thanks to Johana Tablada of MINREX for this compilation.
January 20, 2021

The policy of hostility of Donald Trump’s government against Cuba registered unprecedented measures and actions, which stood out for their systematicity. All spheres of our society and the daily life of citizens suffered the impact of this design, accentuated in the context of the pandemic.

More than 240 measures have been counted. Most of them were actions to tighten the blockade with the aim of economically suffocating the country, subverting the internal order, creating a situation of ungovernability and overthrowing the Revolution.

The emphasis on hindering the main sources of income and hindering our trade relations was notorious in scope.

The main affectations generated by the policy towards Cuba during the Trump administration presented the following behavior:

Title III of the Helms-Burton Act.

The decision to allow lawsuits in U.S. courts under Title III of the Helms-Burton Act was an unprecedented action, after 23 years of successive suspensions of this possibility. This has had an indisputable impact on the prospects of attracting foreign investment, since it constitutes a disincentive that adds to the already existing obstacles due to the regulatory framework of the blockade. So far 28 legal proceedings have been initiated in U.S. courts under the Act.

Travel

The travel sector has been a recurrent target of attack during the Trump administration.

Travel alerts to citizens under the pretext of alleged health incidents were followed by the banning of cruise ship travel, the suspension of the “people-to-people” educational travel subcategory, and the modification of two of the licenses allowing visits by U.S. citizens to Cuba.

The creation of the List of Prohibited Accommodations in Cuba, which included 422 hotels and rental houses, constituted an additional disincentive to travel.

Scheduled and charter flights were cancelled to all parts of the country except Havana, whose frequencies were also limited. The effects of this announcement reached both U.S. citizens and Cuban families.

Remittances

The decision to limit the amount of remittances to US$1,000 per quarter, the suspension of non-family remittances and the prohibition of remittances from third countries through Western Union, imposed greater difficulties on the income of many Cubans.  

The impossibility of processing remittances through Fincimex and AIS eliminated the main formal channels for remittances.

Medical cooperation

Within the framework of the campaign to discredit Cuba’s international medical cooperation and a regional scenario favorable to the right, the U.S. promoted the termination of agreements with several countries in the area and increased pressure on multilateral organizations and third countries. In addition to the undeniable human cost of these actions, the economic impact for Cuba has been considerable.  

Trade and Business

Regulatory changes issued by the Departments of Commerce and the Treasury dismantled existing provisions and created new coercive instruments. The measure preventing the importation of products from any country containing more than 10% U.S. components was reimposed on Cuba. In a globalized economy, this constitutes a real obstacle to acquiring necessary inputs, regardless of the market of origin.

In the interest of curtailing one of the main exportable items, the importation into the U.S. of rum and tobacco of Cuban origin was banned, an announcement that was combined with rhetoric aimed at discrediting those products.      

The creation of the List of Restricted Cuban Entities by the State Department, with which persons subject to U.S. jurisdiction are prohibited from engaging in direct financial transactions, was aimed at hindering foreign trade and the export of goods and services. A total of 231 companies are included in the list.

The decision not to renew the operating license in Cuba of the hotel company Marriot International, in order to sow a climate of uncertainty in the business community, stood out.

The effects on the business system and commercial operations in the country were considerable, as foreign counterparts sometimes interpreted that they could not relate with Cuba or continue operating with entities subject to coercive measures.

Banking-financial sector

A thorough prosecution of Cuba’s banking-financial operations took place during the Trump administration. Of the 22 monetary penalties imposed by the Office of Foreign Assets Control (OFAC) on companies that violated the blockade laws, 9 were against entities in this sector. There was a notable increase in reports of bank account closures, denial of transactions and other obstacles faced by diplomatic and business representations abroad, as a result of US pressures and due to the extraterritorial nature of the blockade.  

Fuel

In parallel to the strategy against Venezuela and under the pretext of Cuba’s alleged interference in that country, measures were adopted against ships, shipping companies, insurance and reinsurance companies linked to the transportation of fuel. In 2019 alone, 53 vessels and 27 companies were penalized. The pressures against the governments of registration or flag of vessels were also notable.

Additional measures

The outline of the policy towards Cuba combined the severe blockade measures with additional actions, which contributed to sustain in time the systematicity of the announcements and creating a climate of permanent aggressiveness. The visa restrictions and other provisions against high-ranking Cuban leaders responded to this objective.

The State Department reports on Human Rights, Religious Freedom, Human Trafficking and Terrorism reinforced the rhetoric against Cuba and the discrediting in these areas.

The arbitrary and unilateral listing pursued the same objective of demonizing and satisfying the demands of the anti-Cuban sectors. The designation of Cuba as a state sponsor of terrorism represented the culminating point in the effort to impede any process of advancement and eventual improvement of bilateral relations.

Donald Trump’s administration. Measures against Cuba
Year Total Extraterritorial Blockade Others

2017
Blocking

June 8 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction against American Honda Finance Corporation (AHFC) for USD 87 255 because one of its subsidiaries in Canada, Honda Canada Finance Inc. approved and financed 13 car leasing agreements between the Cuban Embassy in Canada and a Honda dealership in Ottawa between February 2011 and March 2014. The same company had already rejected, on March 30, 2015, a transfer from the Cuban Embassy in Canada for the replacement of the vehicle fleet that was to be replaced by the company.

On June 26, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction against the US company American International Group (AIG) in the amount of 148,698 dollars for allegedly violating several US government sanctions programs, including the blockade against Cuba. According to the text of the sanction, between 2007 and 2012, AIG engaged in 29 apparent violations of the blockade by providing insurance coverage, various shipments of goods to or from Cuba or related to a Cuban entity, including the processing of premiums or claims arising from that service.

September 8 US President Donald Trump signed a memorandum addressed to the Secretaries of State and Treasury in which he extended for 1 year the application of economic sanctions on Cuba under the legal framework established in the Trading with the Enemy Act of 1917.

September 26 The US Treasury Department’s Office of Foreign Assets Control (OFAC) banned a donation to an NGO in Cuba because the ship carrying the cargo belonged to the US company Norwegian Cruise Line Holdings Ltd.

November 8 The State Department announced the creation of the Cuban Restricted Entities List, in which it included 179 Cuban companies with which US citizens cannot carry out direct financial transactions.

November 8 OFAC announced regulatory changes to the Cuba sanctions program. Individual “people-to-people” educational travel was eliminated.

November 8 OFAC modified the category of educational and support travel to the Cuban people. It established that each traveler must participate in a full-time program of activities involving genuine interaction with individuals in Cuba. These activities must also increase contact with the Cuban people, support civil society in Cuba, or promote the independence of the Cuban people from Cuban authorities.  

November 8 BIS established a general policy of denial of license applications for export items that may be used by entities and sub-entities on the Restricted Cuban Entities List, among other measures. (4 specific measures)

November 17 OFAC imposed a sanction for USD 291,825 to the company BCC Corporate S.A. (BCC), a Belgian subsidiary of BCC. (BCC), a Belgian subsidiary of the US credit card company Alpha Card Group, for selling, between 2009 and 2014, credit cards that were used to make purchases in Cuba. 50% of the shares of Alpha Card Group belong to the U.S. company American Express.

Additional

September Travel Alert for Cuba – level 4

29 September Suspension of visa issuance at consulate in Havana.

May 23 Expulsion of 2 officials from the Cuban Embassy in Washington.

October 3 Expulsion of 15 officials from the Cuban Embassy in Washington.

2018
Blockade

22 February President Donald Trump issued a Presidential Proclamation to extend the state of National Emergency declared by President William Clinton on March 1, 1996 following the downing of two small planes belonging to the group c/r “Brothers to the Rescue”. The proclamation extends through 2019 the ability of the U.S. government to regulate the movement and anchorage of vessels within its territorial waters that will or are likely to travel to Cuba.

Sept. 10 U.S. President Donald Trump signed a memorandum to the Secretaries of State and Treasury extending for 1 year the application of economic sanctions on Cuba under the legal framework established in the Trading with the Enemy Act of 1917.

October 5 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a penalty of $5, 263, 171 on the banking entity J.P. Morgan Chase for conducting unauthorized transactions and providing unauthorized services to clients included in the Specially Designated Nationals and Blocked Persons List between 2008 and 2012.

November 15 The State Department updated the List of Restricted Cuban Entities, with the incorporation of 27 new companies, for a total of 206.

November 19 The banking-financial entity Société Générale S.A. based in Paris, France, agreed to a total payment of US$1,340,231,916.05 to the US Treasury Department’s Office of Foreign Assets Control (OFAC), the U.S. Attorney’s Office for the Southern District of New York, the New York County District Attorney’s Office, the Federal Reserve and the New York State Department of Financial Services for violation of the Cuban Assets Control Regulations, the Iran Sanctions and Transactions Regulations and the Sudan Sanctions Regulations. According to OFAC, Société Générale S.A. processed 796 transactions involving Cuba totaling more than US$5.5 billion between July 11, 2007 and October 26, 2010. This is the fifth sanction applied by the Donald Trump administration and the second to be imposed in 2018.

2019
Blockade

January 16 The U.S. State Department announced through an official notice its decision to suspend for 45 days the application of Title III of the Helms-Burton Act as of February 1. The text of the note states that during this period the U.S. government will study in detail the possibility of implementing or not implementing Chapter III in the future, a decision that will respond to the objectives of “U.S. national security and its commitment to promote the transition to democracy in Cuba”. Likewise, the State Department communiqué mentions the alleged lack of freedoms and human rights violations in Cuba, while emphasizing support for “the corrupt and authoritarian regimes in Nicaragua and Venezuela”. The note concludes by warning those who do business with Cuba, particularly those who “traffic in confiscated properties and are accomplices of the dictatorship”, to reconsider their ties with our country.

February 14 The Office of Foreign Assets Control (OFAC) of the US Treasury Department imposed a sanction of 5 million 512 thousand 564 dollars on the company AppliChem GmbH, based in Darmstadt, Germany for 304 apparent violations of the Cuban Assets Control Regulations. AppliChem, an entity that manufactures laboratory substances and chemicals for industrial use and operates as a subsidiary of U.S.-based Illinois Tool Works Inc, sold its products to Cuba between May 2012 and February 2016 in violation of embargo laws, according to OFAC.

Feb. 19 President Donald Trump issued a Presidential Proclamation to extend the state of National Emergency declared by President William Clinton on March 1, 1996 following the downing of two small planes belonging to the group c/r “Brothers to the Rescue.” The proclamation extends through 2019 the U.S. government’s ability to regulate the movement and anchorage of vessels within its territorial waters that will or are likely to travel to Cuba.

March 4 The State Department announced through an official statement an additional 30-day suspension, until April 17, 2019, of the right to file legal actions under Title III of the Helms Burton Act. However, it communicated that as of March 19, the suspension of these actions will not apply to companies on the Restricted Cuban Entities List.

March 11 The Department of State announced through an official release an update to the Restricted Cuban Entities List, scheduled to take effect as of March 12, 2019. The text of the note points out the incorporation of 5 new sub-entities (Gaviota Hoteles Cuba, Hoteles Habaguanex, Hoteles Playa Gaviota, Marinas Gaviota Cuba) and one entity belonging to Gaviota (Fiesta Club Adults Only, of Blau Marina Varadero). This brings the total to 211 entities.

March 3 The State Department announces the suspension of Title III of the Helms-Burton Act for only 15 days.

April 5 The Treasury Department’s Office of Foreign Assets Control (OFAC) included 34 vessels owned by the Venezuelan oil company PDVSA, as well as two other foreign companies (Ballito Shipping Incorporated, based in Liberia, and ProPer In Management Incorporated, based in Greece) in its list of sanctioned vessels, alleging that they provide services to Caracas for the shipment of crude oil to Cuba.  According to the Treasury Department, the sanctions include the freezing of any financial assets they may have under U.S. jurisdiction and a ban on financial transactions with the listed entities and vessels.

April 9 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction on Standard Chartered Bank, a banking-financial sector entity based in England, for apparent violations of the Cuban Assets Control Regulations and other sanctions programs applicable to Iran, Syria, Sudan and Myanmar. In order to avoid legal action, the British company agreed to pay 639 million 023,750 USD to OFAC and 2,715 million 100,479 USD to other US government and state institutions.

April 11 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction on Acteon Group Ltd. (Acteon), a company based in England, in the amount of US$227,500.

April 11 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction on 2H Offshore (2H Offshore), an entity based in England, for violations of the Cuban Assets Control Regulations. The amount to be paid by the companies is USD 213,866.

April 12 The Office of Foreign Assets Control of the Treasury Department (OFAC) sanctioned 4 companies that operate in the Venezuelan oil sector and 9 vessels that transport Venezuelan crude oil, some of which, during the current year, have transported oil to Cuba.

April 15 The Office of Foreign Assets Control (OFAC) of the Treasury Department imposed a sanction to the German company UniCredit Bank AG.

April 15 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction to the company UniCredit Bank Austria.

April 15 The Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction on the Italian company UniCredit Bank SpA.

April 17 U.S. Secretary of State Mike Pompeo offered statements to the press announcing the full activation of Title III of the Helms-Burton Act as of May 2, 2019.

April 24 The State Department updated the Cuban Restricted Entity List by adding 5 new entities, for a total of 216.

June 4 The Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced regulatory changes to Cuba policy, primarily targeting the travel sector. The measures included the elimination of “people-to-people” travel.

June 4 OFAC announced a policy of denial of licenses for passenger travel (cruise ships), recreational vessels and private aircraft.

June 4 OFAC ruled that U.S. travelers arriving in Cuba under any of the 12 categories may not conduct direct financial transactions with Cuban companies on the Cuban Restricted Entity List. (3 specific measures)

June 13 The Office of Foreign Assets Control (OFAC) of the US Treasury Department imposed sanctions on the US company Expedia Group Inc.

June 13 The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on U.S. company Hotelbeds USA Inc.

June 13 The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department imposed sanctions on the U.S. company Cubasphere Inc. for violations to the Cuban Assets Control Regulations. The three penalties pertained to transactions related to travel or travel services to Cuba.

July 3 The Treasury Department included the company CUBAMETALES in the List of Specially Designated Nationals (SDN) alleging involvement of the Cuban entity in the importation of oil from Venezuela.

July 25 The State Department announced through an official press release an update to the Cuban Restricted Entity List, scheduled to take effect as of July 26, 2019, by including 2 new entities, for a total of 218.

September 6 The Treasury Department’s Office of Foreign Assets Control (OFAC) updated the Cuban Assets Control Regulations by imposing a limit of up to US$1,000 per quarter on family remittances.

September 6 OFAC suspended gift (non-family) remittances.

Sept. 6 OFAC suspended Cuba-related transfers originating and destined outside the U.S. (U-Turn). (3 specific measures)

Sept. 13 President Donald Trump extended for another year the Enemy Trade with Cuba Act for Cuba.

Sept. 17 The Treasury Department’s Office of Foreign Assets Control (OFAC) placed 3 individuals (2 Colombian and 1 Italian national) and 17 companies (12 based in Colombia, 4 in Panama, and 1 in Italy) on the Specially Designated Nationals (SDN) List, alleging they were involved in transporting oil to Cuba.

September 24 The Treasury Department’s Office of Foreign Assets Control (OFAC) included in the Specially Designated Nationals (SDN) List 4 companies (3 Panamanian and 1 Cypriot) and 4 vessels related to the transportation of Venezuelan oil. The companies added were: Bluelane Overseas SA, Caroil Transport Marine LTD, Tovase Development Corp and Trocana World INC; while the vessels were: Carlota, Giralt, Petion and Sandino; all four under Panamanian flag.

October 1 The Office of Foreign Assets Control (OFAC) of the US Treasury Department imposed a sanction of 2 million 718 thousand 581 dollars to the General Electric Company (GE), based in Boston, Massachusetts, for 289 apparent violations of the Cuban Assets Control Regulations. The official statement issued by the Treasury referred that three GE subsidiaries (Getsco Technical Services Inc., Bentley Nevada and GE Betz) accepted payments made by The Cobalt Refinery Company (Cobalt) for goods and services rendered to a GE client in Canada. Cobalt is on the Specially Designated Nationals List.

October 18 The Department of Commerce’s Bureau of Industry and Security (BIS) announced new amendments to the Export Administration Regulations (EAR), scheduled to take effect on October 21. The new measures included a general policy of denying aircraft leasing licenses to Cuban state-owned airlines.

October 18 BIS provided for the prevention of re-export to Cuba of foreign goods containing more than 10% US components.

October 18 BIS announced the revision of the License Exception “Support for the Cuban People” so that certain donations to the government of Cuba and the Communist Party of Cuba cannot be made.

Oct. 18 BIS announced the elimination of authorization for the export of promotional items that “generally benefit the government of Cuba.”

October 18 BIS established that aircraft and vessels are not eligible for the license exception if they are used in charter mode by Cuban nationals or a State Sponsor of Terrorism, or if they are leased by them.

October 18 BIS limited the export of goods intended to improve the telecommunications infrastructure to those that facilitate the “free flow of information” among the Cuban people.  (6 specific measures)

October 25 The U.S. Department of Transportation (DOT) announced the suspension of the export of goods destined to improve telecommunications infrastructure to Cuba. (DOT) announced the suspension of all U.S. airline flights from the U.S. to Cuba, with the exception of those to Havana’s José Martí International Airport. With the measure, which went into effect on December 10, all U.S. flights to nine Cuban airports were suspended. According to the DOT note, this decision was taken at the request of the State Department and stated in a letter sent by Secretary of State Mike Pompeo.

October The most important leaders of the Spanish hotel chain Meliá Hotels International S.A., including its CEO, received notices from the State Department informing them of the prohibition to enter the US, as a consequence of the application of Title IV of the Helms-Burton Act.

November 15 The State Department announced by official release an update to the Cuban Restricted Entity List, by adding 5 new entities, scheduled to take effect as of November 19, 2019, for a total of 223.

November 26 The Treasury Department’s Office of Foreign Assets Control (OFAC) announced the inclusion of the company Corporación Panamericana S.A. on the Specially Designated Nationals (SDN) List.

December 3 The Treasury Department’s Office of Foreign Assets Control (OFAC) announced through an official communiqué the inclusion of 6 vessels (one Panamanian and the rest Venezuelan) in the Specially Designated Nationals (SDN) List for transporting crude oil to Cuba. In addition, it was identified that the vessel “Nevas”, sanctioned since April 2019, had been renamed “Esperanza”, so its entry on the SDN list was updated according to the new denomination.

December 9 The Treasury Department’s Office of Foreign Assets Control (OFAC) announced the settlement to avoid a civil lawsuit, with Chicago-based Allianz Global Risks US Insurance Company, in the amount of $170,535.00 USD.

December 9 The Treasury Department’s Office of Foreign Assets Control (OFAC) announced the settlement of a civil lawsuit with Switzerland-based Chubb Limited in the amount of $66,212.00 USD.  The sanctions are due to apparent violations of the Cuban Assets Control Regulations (CACR) for conducting transactions and other operations related to travel insurance to Cuba.

Additional

January Cancellation of MLB and Cuban Baseball Federation agreement.

March 15 Reduction of the validity of the B2 visa to three months and with a single entry.

June 20 Inclusion of Cuba Level 3 Trafficking Report.

July 26 Visa restrictions on Cuban officials and family members related to Cuban medical cooperation services under Section 212 (a)(3)(C) of the Immigration and Nationality Act.

September 19 Expulsion of 2 officials of the Cuban mission to the UN.

September 26 Inclusion of General de Ejercito and his family on the sanctioned list under section 7031 (c) of the State Department Appropriations, Foreign Operations and Related Programs Act, prohibiting their entry into the US.

September 30 Visa restrictions on Cuban officials associated with international medical cooperation programs under Section 212 (a)(3)(C) of the Immigration and Nationality Act.

November 1 Inclusion of Cuba in annual Presidential Memorandum on Trafficking in Persons and consequent prohibition of federal funding for cultural and educational exchanges, among other measures.

November 16 Inclusion of Minister of the Interior Julio Cesar Gandarilla Bermejo and his children in the list of sanctioned persons under section 7031 (c) of the State Department Appropriations, Foreign Operations and Related Programs Act, which prohibits their entry into the US.

Dec. 20 Cuba placed on a Special Watch List under the International Religious Freedom Act of 1998.

Dec. 31 The Caribbean Confederation of Professional Baseball (CBPC) informed the Cuban Baseball Federation (FCB) that it will not be able to guarantee Cuba’s presence in the Caribbean Series, scheduled for Feb. 1-7 in San Juan, Puerto Rico, after yielding to U.S. pressure.

2020
Blockade

January 10 The U.S. Department of Transportation suspended until further notice all charter flights between the U.S. and Cuba, except those directed to Havana’s “José Martí” International Airport. In a note signed by Secretary of State Mike Pompeo, it is stated that 9 airports currently receiving this service will be affected and that charter operators will have 60 days to discontinue such flights.

January 10 The text adds that, at Pompeo’s request, the Department of Transportation will impose a limit on the number of charter flights directed to the “José Martí” airport. Finally, the statement notes that in the “near future”, the Department of Transportation will present an order with the procedures to implement such limit.

February 25 President Donald Trump issued a notice extending for one year the State of National Emergency related to Cuba, declared by President William Clinton on March 1, 1996, following the downing of the “Brothers to the Rescue” planes.

February 26 The new regulations of the US company Western Union, which eliminates the possibility of sending remittances to Cuba from third countries, went into effect.

May 6 The US Treasury Department’s Office of Foreign Assets Control (OFAC) announced a settlement to avoid a civil lawsuit with the entity BIOMIN America, due to apparent violations of the Cuban Assets Control Regulations (CACR). The amount to be paid by BIOMIN America, an animal nutrition company based in Overland Park, Kansas, is USD 257,862. According to the OFAC document, between July 2012 and September 2017, BIOMIN America and its foreign entities participated without authorization in a total of 30 sales of agricultural inputs produced outside the U.S. to Alfarma S.A. in Cuba, resulting in 44 alleged violations of the CACR.

June 3 The State Department announced the inclusion of seven entities on the Cuban Restricted Entity List, including FINCIMEX. One of the hotels was already incorporated and only its name was updated, so in practice six entities were added, for a total of 229.

June 5 The Treasury Department denied the renewal of the license that allowed Marriott International to operate a hotel in Cuba, while prohibiting the company from developing future business in the country.

July 8 The Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had reached a settlement to avoid a civil lawsuit with the US company Amazon Inc. The company must pay 134,523 dollars for violating multiple sanctions programs maintained by the US government, including that of Cuba. With respect to our country, it is only detailed that “Amazon accepted and processed orders on its websites for persons located in or employed by foreign missions from Cuba, Iran, North Korea, Sudan and Syria”, apparently between 2011 and 2018.

Aug. 13 The U.S. Department of Transportation announced the suspension of all private charter flights between the U.S. and Cuba, except those authorized to Havana and others for emergency medical, search and rescue purposes and those deemed to be in the U.S. interest.

September 9 President Donald Trump extended for one more year the blockade restrictions against Cuba under the Trading with the Enemy Act. The decision was made public through a White House communiqué.

Sept. 24 New Office of Foreign Assets Control (OFAC) amendments to the Cuban Assets Control Regulations (CACR) went into effect. The measures include: Creation of the Cuba Prohibited Accommodations List (CPA List) which will incorporate entities under the ownership or control of the government of Cuba, a “prohibited” official of the government of Cuba, a “prohibited” member of the Communist Party of Cuba, or their immediate family members.

September 24 The importation of alcohol and tobacco products of Cuban origin into the US was restricted.

 September 24 Authorization for persons subject to U.S. jurisdiction to attend or organize professional meetings or conferences in Cuba was eliminated, affecting one of the 12 travel categories approved during the Obama administration.

 September 24 General license authorization for transactions related to public performances, clinics, workshops, sporting and other competitions and exhibitions was eliminated, leaving another of the 12 categories of travel approved during the Obama administration virtually without effect.

 September 28 A new update of the State Department’s List of Restricted Cuban Entities was announced, with the addition of American International Services (aka AIS Remesas), which became effective on September 29. This was the seventh update of the list and the second during 2020, bringing the total number of entities to 230.

 September 30 The Treasury Department’s Office of Foreign Assets Control (OFAC) included Luis Alberto Rodríguez López-Calleja in the Specially Designated Nationals List. With this inclusion, there are now 112 entries related to Cuba on the list.

October 1 The Treasury Department’s Office of Foreign Assets Control (OFAC) made public an agreement to avoid a civil lawsuit with the travel services company registered in New York, Generali Global Assistance, Inc (GGA). The amount to be paid by the entity is USD 5,864,860,000. GGA would have violated the blockade by making transfers related to travel to Cuba through a subsidiary in Canada, between 2010 and 2015.

October 23 The Treasury Department’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to prevent persons subject to US jurisdiction from processing remittances to and from Cuba involving companies included in the State Department’s Restricted List of Cuban Entities. Under these changes, shipments through FINCIMEX and American International Services (AIS) would be prevented.

On November 18, the Department of Transportation denied, at the direction of the State Department, a request by charters Skyway Enterprises, Inc. and IBC to operate flights to Cuba with humanitarian cargo.

On December 21, the Treasury Department’s Office of Foreign Assets Control (OFAC) placed FINCIMEX, GAESA and KAVE COFFEE on the Specially Designated Nationals List.

On December 31, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a sanction on the US company BitGo.

Additional

January 2 Inclusion of FAR Minister Leopoldo Cintra Frias and his sons on the list of those sanctioned under section 7031(c) of the State Department Appropriations, Foreign Operations and Related Programs Act, prohibiting their entry into the US.

May 13 State Department notification to U.S. Congress of certification of Cuba and other countries (Iran, North Korea, Syria and Venezuela) under Section 40A(a) of the Arms Export Control Act as countries that “do not fully cooperate” with U.S. counterterrorism efforts.

July 8 Inclusion of Cuba on list of “foreign adversaries” allegedly engaged in conduct adverse to U.S. national security.

August 6 Inclusion of Cuba in Level 4 of the State Department’s Travel Alert System.

October 1 Presidential directive extending for one year restrictions on federal funding for cultural and educational exchanges to Cuba. Action stemming from Cuba’s continued placement in Tier 3 of the State Department’s Annual Trafficking in Persons Report.

7 December Maintenance on the Special Watch List under the International Religious Freedom Act of 1998, under which the Secretary of State annually designates governments that have “engaged in or tolerated systematic, ongoing, and egregious violations of religious freedom.”

2021
Blockade

On January 1, the State Department included the International Financial Bank on the Cuban Restricted Entities List. The measure would become effective on January 8.

On January 14, the U.S. Department of Commerce announced new export controls on specific technologies and activities that may serve military intelligence in China, Cuba, Russia, Venezuela and other countries that allegedly support terrorism and are subject to U.S. unilateral measures.

On January 14, pursuant to the Department of Commerce’s designation of Cuba as a “foreign adversary,” the Export Control Regulations (EAR) were amended to prohibit certain transactions that pose an undue or unacceptable risk to U.S. national security in information and communications technology.

On January 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced the inclusion of Cuba’s Ministry of the Interior and GB Minister Lazaro Alberto Alvarez Casas on the Specially Designated Nationals List.

Additional

January 11 Inclusion of Cuba on the List of State Sponsors of Terrorism.

14 January Inclusion of Cuba on the Department of Commerce’s list of Foreign Adversaries, by virtue of an executive order signed by Trump.