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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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<img style=" max-width: 100%; height: auto; " width="825" height="347" src="https://www.thompsonhinesmartrade.com/wp-content/uploads/sites/1018/2024/05/Cubaflag-825x347.jpg" class="attachment-lxb_af_3_of_4-wide size-lxb_af_3_of_4-wide wp-post-image" alt="" decoding="async" srcset="https://www.thompsonhinesmartrade.com/wp-content/uploads/sites/1018/2024/05/Cubaflag-825x347.jpg 825w, https://www.thompsonhinesmartrade.com/wp-content/uploads/sites/1018/2024/05/Cubaflag-1100x462.jpg 1100w, https://www.thompsonhinesmartrade.com/wp-content/uploads/sites/1018/2024/05/Cubaflag-550x231.jpg 550w" sizes="(max-width: 825px) 100vw, 825px" />
			On May 28, 2024, the U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) <a href="https://ofac.treasury.gov/media/932896/download?inline" target="_blank" rel="noreferrer noopener">revised</a> the Cuban Assets Control Regulations (CACR) to enhance support for the Cuban people and independent Cuban private sector entrepreneurs. These amendments, effective on May 28, 2024, aim to promote internet freedom and broaden financial services in Cuba. In announcing these amendments, OFAC <a href="https://home.treasury.gov/news/press-releases/jy2374" target="_blank" rel="noreferrer noopener">stated</a> they were &ldquo;in support of internet-based services to promote internet freedom in Cuba, support independent Cuban private sector entrepreneurs, and expand access to certain financial services for the Cuban people.&rdquo; The U.S. Embassy in Cuba issued a <a href="https://cu.usembassy.gov/biden-administration-expands-support-to-the-cuban-people/" target="_blank" rel="noreferrer noopener">press statement</a> providing further details.
The <a href="https://ofac.treasury.gov/media/932896/download?inline" target="_blank" rel="noreferrer noopener">latest amendments</a> to the CACR will be effective on May 29, 2024, and include the following key revisions:
<ul class="wp-block-list">
<li>Internet-Based Services: The scope of authorized internet services has been expanded to include social media, video conferencing, e-learning, and cloud-based services, among others. Training and support for communication-related software development are also enhanced, and restrictions on certain export classifications have been lifted.</li>
<li>Support for Entrepreneurs: The term &ldquo;self-employed individual&rdquo; has been updated to &ldquo;independent private sector entrepreneur,&rdquo; now including private cooperatives and small businesses with up to 100 employees. This change aligns with Cuba&rsquo;s authorization of small- and medium-sized enterprises.&nbsp;However, Cuban officials and Communist Party members are excluded from this definition.</li>
<li>Banking Access: Independent private sector entrepreneurs who are Cuban nationals are authorized to open, maintain, and remotely use U.S. bank accounts, including through online payment platforms, to conduct authorized or exempt transactions, regardless of their location.</li>
<li>U-Turn Transactions: The authorization for &ldquo;U-turn&rdquo; transactions, previously revoked in 2019, has been reinstated.&nbsp;This allows for certain fund transfers involving Cuba to pass through U.S. banks, provided that neither the originator nor beneficiary is under U.S. jurisdiction.</li>
<li>Reporting Requirements for Telecommunications: The amendment replaces the fax or mail reporting requirement for telecommunications-related transactions with an email reporting requirement and clarifies that the reporting requirement applies only to the non-banking institution entity providing telecommunications services.</li>
</ul>
Additionally, OFAC has updated and released new FAQs on its website to assist with the understanding of these changes (See <a href="https://ofac.treasury.gov/faqs/added/2024-05-28" target="_blank" rel="noreferrer noopener">FAQs 1174-1179</a> and <a href="https://ofac.treasury.gov/faqs/search/732+736+745+748+757+769+770+785" target="_blank" rel="noreferrer noopener">FAQs 732, 736, 745, 748, 757, 769, 770, and 785</a>), including a detailed definition of the term &ldquo;independent private sector entrepreneur&rdquo; and examples of authorized services.

OFAC Updates Cuban Regulations to Increase Support for Cuban People

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