Yesterday, the Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to further limit the ability of U.S. persons to book lodging in Cuba, import certain goods from Cuba, and participate in professional meetings or artistic and athletic events in Cuba. The changes include the following:
- The new rules prohibit U.S. persons from staying at, paying for, or arranging for lodging at hotels and other properties that have been identified by the State Department as being owned or controlled by the Cuban government. The State Department is expected to publish a list of properties subject to the restrictions, called the Cuba Prohibited Accommodations List (CPA List), on its website.
- The amendment prohibits U.S. person travelers from bringing Cuban origin tobacco or alcohol products back to the United States.
- The amendment removes the general license at CACR § 515.564(a)(2) that previously authorized U.S. persons to attend and organize certain professional meetings or conferences in Cuba. Under the new rules, U.S. persons wishing to attend or organize meetings in Cuba will likely need to obtain a specific license from OFAC, which will be issued on a case-by-case basis.
- Finally, OFAC narrowed the scope of the general license at CACR § 515.567 to only authorize certain amateur and semi-professional international sporting events in Cuba. Participation in, or organization of, other public performances, athletic competitions, and exhibitions in Cuba will now require a specific license from OFAC, which will be issued on a case-by-case basis.
The travel, hospitality, and sports industries should review their potential exposure to these rule changes and update their internal compliance programs accordingly.