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Alerts and Updates

OFAC Increases Cuba Sanctions with Cap on Family Remittances

September 11, 2019

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The new amendment will extend the prohibitions to include “close family members” of such prohibited parties.

In a notice published September 9, 2019, in Federal Register Vol. 84, No. 174, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced further restrictions on certain transactions involving Cuba and Cuban nationals. The action is in furtherance of National Security Presidential Memorandum-5, signed June 16, 2017.

The amendments to certain provisions of the Cuban Asset Controls regulations restrict family remittances to place a cap of $1,000 as the maximum amount that one remitter can send per quarter to one Cuban national as a family remittance. The recipient of a family remittance may not be a prohibited official of the government of Cuba or a prohibited member of the Cuban Communist Party. The new amendment will extend the prohibitions to include “close family members” of such prohibited parties as defined in 31 CFR Section 515.339 of OFAC’s Cuba Sanctions Regulations.

OFAC is also eliminating certain donative remittances currently authorized by 31 CFR 515.570(b).

In further backing of the U.S. government’s support for certain individuals and independent nongovernmental organizations in Cuba, OFAC is adding a provision to authorize unlimited remittances “to support the development of private businesses, and operation of economic activity in the non-state sector by self-employed individuals, as defined in [OFAC Cuba regulations].”

Please refer to the OFAC notice for a complete review of the regulation amendments.

For More Information

If you have any questions about this Alert, please contact Brian S. Goldstein, any member of the International Practice Group, any member of the Cuba Business Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.