o
U.S. persons may provide goods and services to Cuban national individuals located
outside of Cuba.
o
A number of other activities are authorized, including the provision of (and receipt of
payment for) certain legal services to Cuban nationals, the importation of personal gifts
sent to the United States from Cuba, unblocking of estates in which a Cuban national
has an interest, and various educational activities.
These changes largely are the result of feedback from U.S. companies to U.S. regulators as to the
authorizations needed to implement commercially viable plans to open up communications in Cuba and
to provide support to the Cuban people.
However, Congressional action is still necessary to repeal the
legislative trade embargo and travel ban. The authorizations issued by the Administration today have a
limited scope, and the compliance requirements are highly technical. Thus, U.S.
companies looking to
enter Cuba should undertake a careful review of the Commerce and Treasury regulations applicable to
their business plans.
For more information, please contact:
F. Amanda DeBusk, Partner
+1 (202) 721-4790
amanda.debusk@hugheshubbard.com
Melissa Duffy, Partner
+1 (202) 721-4689
melissa.duffy@hugheshubbard.com
Alan Kashdan, Counsel
+1 (202) 721-4630
alan.kashdan@hugheshubbard.com
International Trade and Customs Practice Group
September 2015
Hughes Hubbard & Reed LLP
One Battery Park Plaza | New York, New York 10004-1482 | +1 212-837-6000
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