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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On October 27, 2020, the U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) <a href="https://www.federalregister.gov/documents/2020/10/27/2020-23725/cuban-assets-control-regulations" target="_blank" rel="noopener noreferrer">published a final rule</a> in the Federal Register amending the Cuban Assets Control Regulations (CACR) to remove from the scope of generally authorized remittances any transactions involving &ldquo;entities or subentities&rdquo; identified on the U.S. Department of State&rsquo;s <a href="https://www.state.gov/cuba-sanctions/cuba-restricted-list/" target="_blank" rel="noopener noreferrer">Cuba Restricted List</a>. The amendment will restrict these entities&rsquo; access to funds obtained in connection with remittance-related activities, including in their role as intermediaries or in their receipt of fees or commissions from processing remittance transactions.&nbsp; The amendment becomes effective on November 26, 2020.
Specifically, the final rule&rsquo;s amendment will directly impact the scope of the following general licenses:
<ul>
<li>31 CFR &sect; 515.570, authorizing certain types of remittances to Cuba from persons subject to U.S. jurisdiction or from blocked accounts;</li>
<li>31 CFR &sect; 515.572(a)(3), authorizing certain travel related and remittance forwarding services; and</li>
<li>31 CFR &sect; 515.587, authoring certain remittances from Cuban nationals to persons subject to U.S. jurisdiction.</li>
</ul>
The rule will also amend 31 CFR &sect; 515.421 (authorizing certain transactions ordinarily incident to licensed transactions) to make clear that a transaction relating to the &ldquo;collection, forwarding, or receipt of remittances&rdquo; involving any entity or subentity identified on the Cuba Restricted List &ldquo;is not authorized as an ordinarily incident transaction where the terms of the general or specific license expressly exclude any such transactions.&rdquo;
As a result of these amendments, effective November 26, 2020, persons subject to U.S. jurisdiction will no longer be authorized to process remittances to or from Cuba through FINCIMEX and AIS or any other entity or subentity on the Cuba Restricted List.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Restricts Remittances to and from Cuba to Exclude Entities on Cuba Restricted List