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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 June 5, 2019, the Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) and the Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) undertook coordinated actions to further restrict travel to Cuba &ldquo;in order to hold the Cuban regime accountable for its repression of the Cuban people and its support of the Maduro regime in Venezuela.&rdquo; Stating that &ldquo;Cuba remains communist, and the United States, under the previous administration, made too many concessions to one of our historically most aggressive adversaries,&rdquo; Commerce Secretary Wilbur Ross said the Trump administration &ldquo;recognizes the threat Cuba&rsquo;s government poses in the region, and ... is acting to limit commercial activity that provides revenue for the Cuban regime.&rdquo; These actions include:
Ending Group People-to-People Travel
<ul>
<li>OFAC amended its <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cacr_20190604.pdf" target="_blank" rel="noopener">Cuba regulations</a> to remove the authorization for group people-to-people educational travel. OFAC&rsquo;s regulatory changes include a &ldquo;grandfathering&rdquo; provision, which provides that certain group people-to-people educational travel that previously was authorized will continue to be authorized where the traveler had already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to June 4, 2019.</li>
<li>OFAC updated its <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_new.pdf" target="_blank" rel="noopener">FAQs</a> pertaining to Cuba.</li>
</ul>
Ending Exports of Passenger Vessels, Recreational Vessels and Private Aircraft
<ul>
<li>BIS amended certain <a href="https://www.govinfo.gov/content/pkg/FR-2019-06-05/pdf/2019-11777.pdf" target="_blank" rel="noopener">Cuba-related provisions</a> under the Export Administration Regulations (EAR) to make passenger and recreational vessels and private and corporate aircraft ineligible for license exception and to establish a general policy of denial for license applications involving those vessels and aircraft. License&nbsp;exception Aircraft, Vessels, and Spacecraft (AVS) has been amended to remove the authorization for the export or reexport to Cuba of most non-commercial aircraft and all passenger and recreational vessels on temporary sojourn. As of June 5, 2019, private and corporate aircraft, cruise ships, sailboats, fishing boats and other similar aircraft and vessels generally will be prohibited from going to Cuba.</li>
<li>BIS updated its <a href="https://www.bis.doc.gov/index.php/documents/pdfs/1568-bis-cuba-consolidated-faqs-3/file" target="_blank" rel="noopener">FAQs</a> pertaining to Cuba.</li>
</ul>
The State Department also issued a <a href="https://www.state.gov/united-states-restricts-travel-and-vessels-to-cuba/" target="_blank" rel="noopener">statement</a> that &ldquo;These actions are directly linked to the tourism industry, which has strong economic ties to the Cuban security, military, and intelligence sectors in Cuba. Veiled tourism has served to line the pockets of the Cuban military, the very same people supporting Nicolas Maduro in Venezuela and repressing the Cuban people on the island. In Cuba, the regime continues to harass, intimidate, and jail Cubans who dare to voice an opinion different from the one the regime wants them to have. The United States calls on the regime to abandon its repression of Cubans, cease its interference in Venezuela, and work toward building a stable, prosperous, and free country for the Cuban people.&rdquo;

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Trump Administration Further Restricts Travel to Cuba