update on u.s. laws regarding commerce with cuba · 5/17/2016  · jennifer r. diaz, esq....

UPDATE ON U.S. LAWS REGARDING COMMERCE WITH CUBA

Jennifer R. Diaz, Esq.

Jen@diaztradelaw.com

Board Certified International Attorney

Founding Partner

Diaz Trade Law, P.A.

Office: (305) 456-3830

Cell: (305) 724-3281

Caribbean Shipping Association

Cocoa Beach, FL

May 17, 2016

DISCLAIMER

• This presentation is for informational purposes only and does not purport

to provide legal advice as all cases and facts are different.

• The information in this presentation is provided “as is” and no

representations are made whatsoever.

• You should not rely on the information included in this presentation as an

alternative to legal advice from your attorney.

• For questions related to a specific matter, you should consult your

attorney.

• To the extent permitted by law, this presentation is Copyright © 2013-

2015 by Diaz Trade Law, P.A.

AGENDA

Cuba Update!

• Background

• U.S. Federal Agencies Involved

• Summary of Changes

• What’s legal NOW?

• Major Impacts to Business

• Top Tips!

• Resources

POLLS ON CUBA SUPPORT

Polls of Cuban-Americans

Polls of Cuban-Americans

AUDIENCE POLL

• Are you in favor of an end to the travel ban?

• Of an end to the embargo?

THE U.S. REGULATIONS

COMMONLY REFERRED TO

AS THE “U.S. EMBARGO”

PROHIBITS FREE TRAVEL

TO CUBA.

Primary Legal Authority & OtherSupporting Laws & Regulations

• Trading with the Enemy Act of 1917 (TWEA)• Proclamation 3447 - Embargo on all Trade with Cuba

(Feb. 1962)• The Cuban Assets Control Regulations, 31 CFR Part

515 (July 1963)• Export Administration Regulations (EAR) (15 CFR

730 et seq.)• The Cuban Democracy Act of 1992• The Cuban Liberty and Democratic Solidarity (Libertad)

Act of 1996• Trade Sanctions Reform and Export Enhancement Act of

2000

U.S. Federal Government Agencies –Key Players

• Treasury Department’s Office of

Foreign Assets Control (OFAC)

• Cuban Assets Control Regulations

(CACR)

• (31 C.F.R. Part 5151)

• Commerce’s Bureau of Industry and

Security (BIS)

• Export Administration Regulations

(EAR)

• (15 C.F.R. Parts 730-774)

OFAC’s Jurisdiction Includes Both Persons And Property Subject To U.S. Jurisdiction

Persons include:

Individuals• U.S. citizens and permanent resident aliens located • anywhere in the world• Individuals, regardless of citizenship, physically • located in the United States

Entities • Organized under U.S. law, including foreign branches of U.S. companies• Physically located in the U.S., including U.S. branches, agencies and • representative offices of foreign corporations• Owned or controlled by a U.S. citizen, lawful permanent resident, or entity organized under

U.S. law.

BIS Jurisdiction & License Requirements

• Exports and reexports of commodities, software, and

technology (i.e., items)

• License requirement for exports and reexports of all

items subject to the EAR unless authorized by license

exception (§ 746.2(a))

• General 25 percent de minimis level for foreign-made

items located abroad

(§ 734.4)

Poll:

• What date did President Obama announce the U.S. will lay

out “ a new course in our relations with Cuba?”

A. December 17, 2014

B. January 17, 2014

C. January 1, 2015

D. February 1, 2016

Answer:

• What date did President Obama announce the U.S. will lay

out “ a new course in our relations with Cuba?”

A. December 17, 2014

IMPORTANT DATES– December 17, 2014 –

• Pres Obama announced the U.S. will lay out “a new

course in our relations with Cuba.”

– January 16, 2015 –

• Revised Cuba Regulations were officially released by

OFAC and BIS

– April 14, 2015 –

• President Obama announced his decision to REMOVE

Cuba from the State sponsor of terrorism designation

– September 21, 2015 –

• Additional Revised Cuba Regulations were officially

released by OFAC and BIS

– January 27, 2016 –

• Additional Revised Cuba Regulations were officially

released by OFAC and BIS

– March 16, 2016 –

• Additional Revised Cuba Regulations were officially

released by OFAC and BIS

December 17, 2014 Promise

• Re-establishing diplomatic ties

by creating a U.S. Embassy

• Reviewing Cuba’s designation

as a State Sponsor of

Terrorism

• Facilitating remittances to Cuba

by U.S. persons

January 16, 2015 Major Changes

1. Travel

2. Telecom

3. Building Materials, Tools,

Equipment and Supplies

4. Financial Services

5. Personal Imports

January 16, 2015 Changes - Travel

• 12 categories of Travel Now Falling Under a

General License:

1. Family visits

2. Official business of the U.S. government, foreign

governments, and certain intergovernmental

organizations

3. Journalistic activity

4. Professional research and professional meetings

5. Educational activities

6. Religious activities

7. Public performances, clinics, workshops, athletic

and other competitions, and exhibitions

8. Support for the Cuban people

9. Humanitarian projects

10. Activities of private foundations or research or

educational institutes

11. Exportation, importation, or transmission of

information or information materials

12. Certain export transactions that may be

considered for authorization under existing

regulations and guidelines

Want More Information About the Original January 16, 2015 Changes?

Email info@diaztradelaw.com

for a copy of the article or go to

www.diaztradelaw.com

April 14, 2015 TOP IMPACTS OF CUBA BEING REMOVED FROM

“TERRORISM LIST?

(1) Perception

(2) Credit

(3) Diplomacy

(4) Trade

July 20, 2015

• The Embassy of the United States of America

re-opened in Havana and the Cuban

Embassy re-opened in Washington, D.C.

September 21, 2015 Changes

OFAC:

• Authorized travelers can get to Cuba by “Vessel”

• Vessel can offer certain lodging services.

• “Close Relatives” can join

• Can open bank account for “authorized

transactions”

BIS:

• New Exception “Aircraft, Vessels, and Spacecraft”

(AVS) will authorize temporary sojourns to Cuba

of cargo vessels for hire for use in the

transportation of items

-Travel Related:

September 21, 2015 Changes

-Telecommunications & Internet

• OFAC has authorized the importation into the U.S. Cuban-Origin mobile applications and the employment of Cuban national by persons subject

to U.S. jurisdiction to develop mobile applications, as well as authorizing

persons subject to U.S. jurisdiction to provide services related to all such items

that were exported to Cuba

September 21, 2015 Changes

OFAC

• Now allows all persons subject to U.S. jurisdiction to provide goods and services to

Cuban national individuals located in a third country and banking institutions to

open, maintain, and close bank accounts for such Cuban nationals.

• Physical Presence and Operations in Cuba (The amendments authorize certain

listed activities to maintain physical presence (e.g., office space, warehouse, and

outlet space) in Cuba.)

September 21, 2015 Changes

Support for the Cuban People License

Exception (SCP) now includes:

• Leases and loans

• Temporary exports

Remittances

• Removed limit on

donative remittances

September 21, 2015 Changes

• Legal Services to Cuba and Cuban

Nationals (To comply with US laws,

before US courts)

• Gift Imports

• Educational Activities

• Ordinarily Incident Transactions

• Air Ambulances and Emergency

Medical Services

• Humanitarian Projects

• Supporting Diplomatic Relations

WHAT ARE THE MAJOR CHANGES FROM JANUARY 27, 2016?

• Financing

• More Travel

• BIS General Approval and Denial

Policy

• The list of authorized humanitarian

projects has been expanded by

OFAC to include projects that focus

upon disaster preparedness, relief,

and response.

Major Travel Changes from February 16, 2016:

Air Carriers

• On February 16, 2016, The United States and Cuba signed an

agreement allowing commercial air traffic to resume between

the countries for the first time in fifty years.

• New flights are expected to operate daily by next fall (up to 110

daily roundtrip flights from the U.S.!).

• U.S. visitors to Cuba will still have to qualify under one of the

travel categories legally authorized by the U.S. government.

WHAT ARE THE MAJOR CHANGES FROM MARCH 16, 2016?

Travel & Related Transactions• Build Your Own People-to-people educational travel

• Payment of salaries

• Cuban-origin merchandise

WHAT ARE THE MAJOR CHANGES FROM MARCH 16, 2016?

Banking & Financial Services• U-turn payments through the U.S.

financial system• Processing of U.S. dollar monetary

instruments• S. bank accounts for Cuban nationals

Trade & Commerce • Physical and business presence• Importation of software• Cuban private sector

Grants & Awards• OFAC will authorize the provision of

educational grants and awards

BIS’ March 16, 2016 Changes

• License Exception AVS:

The new rule allows for

vessels departing the

United States on temporary

sojourn to Cuba with cargo

for other destinations

POLL

Is travel to Cuba for

tourism authorized?

POLL

Is travel to Cuba for tourism reasons only authorized?

- No!

Despite what you see on Facebook

Travel, that is allowed!

• Tourism = NO!

• 12 General License / Authorized Traveler Categories:

1. family visits;

2. official business of the U.S. government, foreign governments, and certain

intergovernmental organizations;

3. journalism;

4. professional research and professional meetings;

5. educational;

6. religious;

7. public performances, clinics, workshops, athletic and other competitions, and

exhibitions;

8. support for the Cuban people;

9. humanitarian projects;

10. activities of private foundations or research or educational institutes;

11. exportation, importation, or transmission of information or information materials;

and

12. certain export transactions that may be considered for authorization under existing

regulations and guidelines.

TOURISM GROWTH!

• Tourism is one of Cuba’s key sources of revenue, generating

nearly $2.4 billion of income.

• Close to 1 million visited the island in just the first quarter of 2015,

according to the country’s Tourism ministry

• Both American and United Airlines have expressed interests in

making direct flights to the island. So have Delta and Southwest!

POLL

What major cruise line is planning to cruise to

Cuba in the near future?

ANSWER

What major cruise line is planning to cruise to

Cuba in the near future?

• Carnival Cruise Lines – Fathom (May 1, 2016)

CARNIVAL GETS APPROVAL TO CRUISE TO CUBA STARTING IN MAY 2016

• This will be the first time in over 50 years that a cruise ship will be allowed to

travel from the US to Cuba.

“Today we’ve made history,” said Arnold Donald, CEO of Carnival Corp., in a call

from Havana. “This is a historic opportunity, and we know there is pent-up

demand amongst Americans who want to experience Cuba.”

CARNIVAL CRUISE LINES: MAJOR SHIP WILL DOCK IN CUBA MAY 2016

AIRBNB

• Airbnb - April 1.

• Nate Blecharczyk, co-founder and CTO of Airbnb:

• “It’s not a meaningful revenue source now.” [But] “Maybe over

time.” Still, the company is putting significant marketing

muscle to advertise its presence in Cuba.

• There are several reasons for the push. “Most people expect

the number of travelers coming to Cuba to greatly increase,”

Blecharczyk says. “In that case, Airbnb can play a role in helping

Cuba accommodate many more travelers. It could become a

case study.”

STARWOOD HOTELS WILL RENOVATE AND RUN THREE CUBAN HOTELS

• Starwood Hotels will renovate and run three Cuban hotels, which will return U.S. hotel chains to

the island more than 50 years after all American hotels were taken over by Fidel Castro.

• All Cuban hotels are state-owned

• A hotel owned by the tourism arm of the Cuban military will become a Sheraton Four Points.

• Specific License

POLL

• How long should you keep records of

your travel to Cuba?

ANSWER

• 5 Years

Diaz Trade Law Top Travel Tips!

1. KEEP RECORDS (we DON’T know who the next President will be, or what their stance on Cuba is) for 5 Years.

2. Ensure you DO meet one of the 12 “Authorized Traveler” Categories. NO purely “touristic” visits. ConsultOFAC’sFAQ’s, if still unsure, contact your lawyer to determine if you fit into one of the 12

3. Make sure you have a travel agenda detailing your appointments (if they don’t fill up a “FULL DAY,” you’re not done drafting it, and maybe will need a travel sponsor for your people to people mission after all).

4. If you’re participating in a ‘People to People’ mission, ask yourself (hint, at least one answer should be YES), does this agenda seek to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities?

5. If you’re participating in a ‘People to People’ mission, check your agenda PRIOR to traveling; predominantly meeting with the government of Cuba or Cuban Communist Party Officials will NOT be an authorized trip.

POLL

• Can I purchase Cuban-

origin cigars and/or Cuban-

origin rum or other Cuban-

origin alcohol over the

internet?

• What about on vacation in

Europe?

ANSWER

• No – Online

• Yes – in Europe (515.204)

PERSONAL IMPORTS

“Authorized travelers” to Cuba are authorized to import

into the U.S. $400 worth of goods from Cuba, of which

no more than $100 can consist of tobacco products and

alcohol combined, for personal use only.

GOODS AND SERVICES THAT CAN BE IMPORTED FROM CUBA

• The State Department’s Section

515.582 List

• Categories of goods that are not

eligible for import into the United

States

• Any other goods produced by

independent Cuban

entrepreneurs and not covered

by the listed sections and

chapters of the HTS may be

imported

REMOVAL OF THE DOLLAR TAX IN CUBA

Recently, the U.S. lifted a ban on Cuban access to the global bankingsystem, a longstanding Cuban demand. Foreign Minister BrunoRodriguez told reporters that Cuba will attempt a series of internationaltransactions in coming days. If they work, Cuba will eliminate the 10percent penalty (on converting U.S. dollars).

OBAMA’S MARCH 2016 TRIP TO CUBA

• Rolling Stones, Baseball, Interviews and more.

“Havana is only 90 miles from Florida, but to get here, we had to travel a great distance,

over barriers of history and ideology, barriers of pain and separation,” Obama said in

the address televised across Cuba. “I have come here to bury the last remnant of the

Cold War in the Americas.”

DO CUBAN ENTREPRENEURS RECEIVE A LICENSE FROM THE CUBAN GOVERNMENT?

• Persons subject to U.S. jurisdiction

importing goods, or involved in

specific business transactions, are

required to obtain evidence that

demonstrates the Cuban

entrepreneur’s independent status,

and, in the case of an entity, that the

entity is private (i.e., not owned or

controlled in whole or in part by the

Cuban government).

CUBAN ENTREPRENEURIAL JOBS / Cuentapropistas (Self-Employed)

• Accountant

• Animal Caretaker

• Automobile Battery Repair

• Barber

• Bus/Train/Taxi Stop Barker

(calls out instructions to

waiting passengers)

• Button Coverer (wraps

buttons in cloth, popular in

the 50’s and 60’s)

• Engraver of Numbers

• Flower Wreath Arranger

• Folkloric Dancers

• Fortune Tellers

• Restaurant Owner (paladares)

• Used Book Seller

• Knife Grinder

• Piñata Maker/Seller

• Producer/Seller of Brooms and Brushes

• Small-Truck Driver

• Car Body Remolding

• Car Painter

• Car washer/Oil Changer

Since the Changes We have Seen Growth in the Cuban Economy

POLL

• Is your spouses father in law a close

relative according to OFAC?

POLL

• No. A close relative has to – share a

dwelling and be related by blood, marriage

or adoption (no more than 3 generations

removed). (515.561)

POLL

• Can my close relatives accompany me

on a trip that I am authorized to take to

Cuba?

ANSWER

• Yes, if:

You share a dwelling and are related

by blood, marriage or adoption (no

more than 3 generations removed).

(515.561)

Banking in Cuba

American Express and MasterCard said they'll let

customers use their credit cards in the country.

• Stonegate has confirmed it now has a debit card that will work in Cuba

• American Express (AXP) is still reviewing the new regulations and a spokeswoman

could not say when exactly the change would take place. According to the

spokeswoman: ”The end goal is to do business there," she said.

• MasterCard (MA) has said that customers will be able to use their credit cards in

Cuba

• Still, people should contact their bank before traveling to ensure that their card will

be supported there, the company said in a statement last week.

Telecom!

• Numerous transactions are now authorized without a

license!

CUBAN INTERNET ISSUES

• Only about 13% of Cubans have computers at home, and barely 5% have internet access.

• Fewer than 1 in 5 have mobile phone subscriptions, according to the United Nations

GOOGLE OFFERS FASTER INTERNET IN CUBA

• Google is opening a cutting-edge online technology center at the studio of one

of Cuba's most famous artists, offering free Internet at speeds nearly 70 times

faster than those now available to the Cuban public.

POLL

• How much does

WiFi cost in public

areas across

Cuba?

ANSWER

• $2 per hour!

INTERNET GROWTH IN CUBA?

•In July, Cuba’s state-run telecom ETECSA installed Wi-Fi in 35 public areas across the Caribbean island

POLL

• How many

broadband internet

accounts are in

Cuba?

ANSWER

• 5,300

Netflix

• “We are not in contact with the Cuban government on content,” said Netflix spokeswoman Kari Perez. “As we do globally, what content we show depends on our licensing rights. The announcement shows our confidence in the reforms underway in Cuba and that loosened restrictions on US businesses will lead to investments in the country, including infrastructure improvement.”

• Netflix has become one of the first companies to enter Cuba’s nascent digital entertainment industry, although few consumers are likely to immediately enjoy the benefits. $8/Month

• There are only 5,300 broadband internet accounts on the Caribbean island, where low wages mean Netflix’s streaming of television and film content will cost almost half of an average Cuban’s monthly wage.

• Netflix has also stated that it wouldn’t accept Cuban Pesos, thus Cuba’s two-tiered system could create many problems on both sides

Communications

IDT Corp and the Cuban state firm ETESCSA have Agreed to Direct Connect

• Both companies have agreed to direct connect phone calls between the two

countries

• Previously, calls had to go through third countries such as Italy and Spain

• Boost Mobile, part of Sprint Corp., has also launched a prepaid plan allowing

US customers to call and text Cuba directly, which is the first of its kind.

Remittances - POLL

• What is the total U.S. dollar amount of remittances sent to Cuba

from the United States in 2013?

• In 2014?

• Projected from 2015?

Remittances - POLL

• What is the total U.S. dollar amount of remittances sent

to Cuba from the United States in 2013?

$2.8 Billion

• In 2014?

$3.13 Billion

• Projected from 2015?

$3.99 Billion

CUBA HAS LONG HAD A MAXIMUM WAGE OF ABOUT $20 A MONTH.

• Remittances from the United States have been helping fuel private enterprise on

the island

• The limits on donative remittances to Cuban nationals other than prohibited

Cuban Government or Cuban Communist Party officials, was removed

entirely.

• The limits on authorized remittances that individuals may carry to Cuba,

previously $10,000 for persons subject to U.S. jurisdiction and $3,000 for

Cuban nationals, was also removed entirely.

“Someone receiving a remittance of $5,000, for

example, from the United States can go and

start a business or buy a small apartment,” said

Odilon Almeida, Western Union’s president for

the Americas and the European Union. “I think

remittances are changing Cuba faster than is

perceived today.”

Building Materials!

• The following commercially sold or donated items maynow be exported to Cuba without a license

Building in Cuba

The USA Today reported,

that a Cuban-American civil

trial lawyer that established

a business that sells

construction materials to

entrepreneurs in Cuba said,

"We're entering a very dark

room and feeling out way

through to get to the other

side."

POLL

• Can you guess

what the average

monthly salary in

Cuba is?

ANSWER

• Can you guess what

the average monthly

salary in Cuba is?

$20

Summary of 5 Major Changes Impacting U.S. Business –Potential Opportunities

• Travel

• Carrier service by vessel and certain lodging services — 31 CFR 515.572

• Personal imports - 31 C.F.R. 515.582

• Finance

• Bank accounts for authorized travelers. — 31 CFR 515.560 to allow all authorized travelers to open and maintain bank accounts in Cuba in order to access funds while located in Cuba for authorized transactions, and to close such accounts.

• Telecommunications

• Subsidiaries, joint ventures, and other business relationships with Cuban individuals and entities. In order to further enhance the free flow of information to, from, and among the Cuban people and to better provide efficient and adequate telecommunications services between the United States and Cuba — 31 CFR 515.542 and 515.578

• Remittances

• 31 CFR 515.570(b) to remove the limitation on donative remittances

• 31 CFR 515.560(c)(4)(i) to remove the limitation on certain authorized remittances that authorized travelers may carry to Cuba

• Building Materials

• 15 CFR § 740.21 — New License Exception Support for the Cuban People (SCP) , among other provisions, authorizes the export and reexportto Cuba, without a license, of certain commercially sold categories of items:

• building materials, equipment, and tools for use by the private sector to construct or renovate privately-owned buildings, including privately-owned residences, businesses, places of worship, and buildings for private sector social or recreational use;

• tools and equipment for private sector agricultural activity; and

• tools, equipment, supplies, and instruments for use by private sector entrepreneurs.

• Items eligible for this provision must be designated as EAR99 or controlled on the Commerce Control List (CCL) (15 CFR Part 774,Supplement No. 1) only for antiterrorism (AT) reasons.

REALITIES

• Average Monthly salary in Cuba is $20/month

• In most cases. U.S. persons can ONLY do business with

“PRIVATE” entrepreneurs in Cuba (difficult to prove one

is “Private”)

• Financial institutions are still cautious

• Still need Specific Licenses for MOST transactions

• PATIENCE is required for business in Cuba

Top 10 Tips When Exporting To Ensure Compliance

• Export Compliance Steps

1. What is YOUR product?

i. Know your product and Supplier

ii. Request samples in advance of exportation

2. Which agency regulates YOUR product?

3. What is YOUR product classification? Classify your product correctly according to the Commerce Control List (CCL) or the United States Munitions List (USML)

4. Does YOUR product need a license?

5. Ensure the end user is not prohibited, Ensure the end uses are not prohibited

6. Check Consolidated List at http://export.gov/ecr/eg_main_023148.asp

• Ensure you have a Formal Written Compliance Program!!!

• DO your DUE DILIGENCE!

For a copy of the TOP 10 TIPS WHEN EXPORTING go to www.diaztradelaw.com

Customs & Trade Blog

• SUBSCRIBE TODAY AT:

http://customsandinternationaltradelaw.com/

Cuba Blogs

• Build Your Own ‘People to People’ Mission & More Cuba Changes, March 1, 2016

• Up to 110 Daily Flights from the U.S. to Cuba, February 23, 2016.

• Top 10 Changes with Cuba as a Result of MORE NEW Revised OFAC and BIS Regulations, February

5, 2016

• Update on U.S. Laws Regarding Commerce with Cuba, November 25, 2015

• “TOP 11 NEW Business Opportunities with Cuba as a Result of NEW OFAC and BIS

Laws, September 28, 2015

• 3 Part Seminar Series You DON’T Want to Miss!, August 6, 2015

• Embassies and Island Wide Wi-Fi by July in Cuba, July 1, 2015.

• Doing Business in Cuba: What’s Next? Live Webinar, June 23, 2015.

• Top Impacts of Cuba Being Removed From “Terrorism List”, May 29, 2015.

• Hear How Companies are SUCCESSFULLY Doing Business with Cuba, May 14, 2015.

• In Tampa? Meet the Expert, May 12, 2015.

• OFAC Publishes NEW FAQ on Cuba, April 16, 2015.

• Urban Land Institute Discusses New Trading Opportunities with Cuba, April 2, 2015.

• Revised Cuba Regulations Officially Released, January 16, 2015.

• TOMORROW Updated Cuban Assets Control Regulations Take Effect, January 15, 2015.

• TOP Questions and Answers on Obama’s Cuba Announcement, December 19, 2014.

• Congressional Response to President Obama’s Announcement on Future Relations with

Cuba, December 18, 2014.

• Business with Cuba – What’s Legal and What’s Not?, December 17, 2014.

Resources

• OFAC

• New Law

• https://www.federalregister.gov/articles/2016/03/16/2016-

06018/cuban-assets-control-regulations

• Frequently Asked Questions Related to Cuba

• https://www.treasury.gov/resource-

center/sanctions/Programs/Documents/cuba_faqs_new.pdf

• BIS

• New Law

• https://www.federalregister.gov/articles/2016/03/16/2016-06019/cuba-

revisions-to-license-exceptions-and-licensing-policy

• Frequently Asked Questions Related to Cuba

• https://www.bis.doc.gov/index.php/forms-

documents/doc_download/1446-bis-cuba-consolidated-faqs

More Resources• Unverified List

• http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-

concern/unverified-list

• Entity List

• http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-

concern/entity-list

• Specially Designated Nationals List

• http://www.treasury.gov/resource-center/sanctions/SDN-

List/Pages/default.aspx

• U.S. Munitions List

• http://pmddtc.state.gov/regulations_laws/documents/official_itar/ITAR

_Part_121.pdf

• Commodity Jurisdiction requests

• http://pmddtc.state.gov/commodity_jurisdiction/index.html

• OFAC – Specific License Request

• https://www.treasury.gov/resource-

center/sanctions/Pages/licensing.aspx

• D-Trade Information Center

• http://pmddtc.state.gov/DTRADE/index.html

About Us

• Diaz Trade Law• http://www.diaztradelaw.com/

• Cuba Experience• http://diaztradelaw.com/cuba/

• Cuba VIDEO• https://youtu.be/FfDyrZZqTQ4

• Diaz Trade Law Blog• http://diaztradelaw.com/news-articles/

• Jennifer R. Diaz• http://diaztradelaw.com/jennifer-diaz/

ANY QUESTIONS?

UPDATE ON U.S. LAWS REGARDING COMMERCE WITH CUBA

Jennifer R. Diaz, Esq.

Jen@diaztradelaw.com

Board Certified International Attorney

Founding Partner

Diaz Trade Law, P.A.

Office: (305) 456-3830

Cell: (305) 724-3281

Caribbean Shipping Association

Cocoa Beach, FL

May 16-18, 2016