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DoD Eases Procurement Restrictions on Cuba-Owned Firms

By Thad McBride & Todd Overman on November 3, 2015
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A final rule issued on October 30, 2015 removes Cuba from the definition of “state sponsor of terrorism” in two DFARS clauses. The new rule implements the State Department’s action to remove Cuba from the List of State Sponsors of Terrorism. The new rule affects DFARS 252.255-7049, Prohibition on Acquisition of Commercial Satellite Services from Certain Foreign Entities – Representations; and DFARS 252.255-7050, Disclosure of Ownership or Control by the Government of a Country that is a State Sponsor of Terrorism.

Firms in which Cuba has an ownership interest are now eligible to provide commercial satellite services to the United States government. Contractors are also no longer required to disclose ownership or control by the Cuban government in a firm or its subsidiary, and such firm is no longer prohibited from receiving an award (previously, a waiver from the Secretary of Defense was necessary to overcome this prohibition).

These actions stem the President’s December 2014 direction to the State Department to review and report on Cuba’s designation as a State Sponsor of Terrorism in an effort to continue the new path for U.S.-Cuba relations. As mentioned in our April 14 blog post, the State Department recommended rescinding Cuba’s designation, and the Administration submitted its intent to Congress to do so on April 14, 2015.

Read more on what this means for future business in Cuba in our April 14 and August 10 updates.

Photo of Thad McBride Thad McBride

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP)…

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.

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Photo of Todd Overman Todd Overman

Todd Overman is the chair of the firm’s Government Contracts practice and Managing Partner of the Washington, D.C. office.  He has over twenty years of experience advising companies on the unique aspects of doing business with the federal government. Over the last decade…

Todd Overman is the chair of the firm’s Government Contracts practice and Managing Partner of the Washington, D.C. office.  He has over twenty years of experience advising companies on the unique aspects of doing business with the federal government. Over the last decade, he has advised on more than 50 transactions involving the purchase or sale of a government contractor.

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  • Posted in:
    Government Contracts
  • Blog:
    GovCon & Trade
  • Organization:
    Bass, Berry & Sims PLC
  • Article: View Original Source

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