Early in his presidency, President Donald Trump undertook a review of U.S. policy toward Cuba and announced, via a presidential memorandum in June 2017, revisions to that policy to once again restrict certain travel and limit the sale of goods and technology that might benefit the Cuban military. (See Trump and Trade Update of June 20, 2017.) In November 2017, the Departments of Commerce and the Treasury implemented regulatory changes to the United States’ longstanding Cuba sanctions that had been revised and relaxed under President Obama. (See Treasury’s Fact Sheet and Commerce’s Cuba web page.) The Trump administration’s actions sought to tighten sanctions against the Cuban military and intelligence services, including their holding companies, and to increase sanctions related to traveling to and conducting business in Cuba.
In early November 2018, National Security Advisor John Bolton gave a speech in Miami on U.S. policy toward Latin America. He labeled Cuba, Venezuela and Nicaragua the “Troika of Tyranny in this hemisphere,” stating that these countries are the “cause of immense human suffering, the impetus of enormous regional instability, and the genesis of a sordid cradle of communism in the Western Hemisphere.” Under the Trump administration, Bolton stated, the United States will continue to “maintain sanctions until, among other things, all political prisoners are freed, freedoms of assembly and expression are respected, all political parties are legalized, and free and internationally supervised elections are scheduled.” In the coming weeks, he further noted, additional entities owned or controlled by the Cuban military and intelligence services will be added to the restricted list of entities with which financial transactions by U.S. persons would be prohibited.
On November 15, 2018, the Department of State released a fully updated list of sanctioned Cuban entities, including 30 new entities and newly identified subentities of previously listed companies. U.S. companies that continue to conduct limited and licensed business activities in Cuba should be certain to screen all parties to their transactions against this updated list.