On 21st October, Sandler Travis Rosenberg reported that the Bureau of Industry and Security has issued a final rule amending the Export Administration Regulations to further restrict exports and re-exports of items to Cuba.  These changes are being implemented in an effort to further restrict the Cuban government’s access to items subject to the EAR, thereby supporting the Trump administration’s policy.  The article lists that changes being made, including –

  • a general policy of licence denial for leases of aircraft to Cuban state-owned airlines;
  • aircraft and vessels are not eligible for a licence exception if they are leased to or chartered by a national of Cuba or a state sponsor of terrorism;
  • a general 10% de minimis level for Cuba exports control;
  • making the Cuban government and communist party ineligible for certain donations;
  • removing an authorisation for promotional items that generally benefits the Cuban government; and
  • clarifying the scope of telecommunications items that the Cuban government may receive without a licence.


This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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