The US has imposed a trade embargo against Cuba which prohibits most transactions between US persons/entities and Cuban nationals. Members should note that these sanctions also apply to non-US entities which are owned or controlled by US persons.
The main sanction which has been imposed which affects the club’s membership, is a prohibition on vessels calling at US ports for 180 days after trading to a port in Cuba. Further details are provided in a client alert issued by Freehill Hogan & Mahar LLP here.
In October 2016 the Cuban Asset Control Regulations (CACR) were amended to create an exception to this ‘180 day rule’, for foreign vessels. Under the terms of the exception, a foreign vessel is exempt from the 180 day rule if it carries to Cuba from a third country, goods which are subject to the US Export Administration Regulations (classified as EAR99).
FAQs issued by US OFAC
Alerts issued by Freehill Hogan & Mahar LLP are available here