The State Department has published an updated list of entities and sub-entities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel and with which direct financial transactions would disproportionately benefit such entities at the expense of the Cuban people or private enterprise in Cuba. This update includes four additional subentities.
Persons subject to U.S. jurisdiction are generally prohibited from engaging in certain direct financial transactions with entities and sub-entities on the Cuba restricted list. In addition, the Bureau of Industry and Security will generally deny applications for licenses to export or reexport items for use by such entities or subentities.
For more information on what may and may not be exported to Cuba, please contact export compliance attorney Kristine Pirnia at (202) 730-4964.
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