On 21st October, Arent Fox published an article saying that the US Commerce Department’s Bureau of Industry and Security announced another major policy change towards Cuba by further restricting the Cuban government’s access to items subject to US export controls.  The change will have a significant impact on exporters and re-exporters currently using certain licence exceptions to export to Cuba, who export non-US origin products with US-origin content to Cuba, and who lease commercial aircraft to Cuban state-owned airlines.  It also has potential implications for non-US airlines who fly to other countries (e.g. Iran, Syria, Sudan and North Korea).  The article details the new restrictions, which include aircraft and vessels are not eligible for a licence exception for aircraft, vessels, and spacecraft (AVS) if they are leased to or chartered by a national of Cuba or a State Sponsor of Terrorism, and it removes BIS’s general policy of approval for applications to export or re-export aircraft leased to Cuban state-owned airlines, and for the the export or re-export of certain aircraft and vessels on temporary sojourn.  The article ends by providing guidance for companies which have been exporting or re-exporting from third countries to Cuba under one of the licence exceptions, or you have been re-exporting foreign-made items incorporating US-origin controlled content under de minimis.

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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