OFAC guidance on Cuba 180-day rule and Cuba de-listings

OFAC has updated its FAQ on US sanctions against Cuba to provide guidance on the “180-day rule” that applies to vessels visiting Cuba (FAQs 86-90, link here), and has also de-listed several people and entities from its Cuba sanctions. The 180-day rule prohibits any vessel that enters a port or place in Cuba with the purpose of trading in goods or services from loading or unloading freight at a US port for 180 days after it leaves Cuba.

The new guidance sets out several exceptions to the 180-day rule, including when the trade was authorised under the Cuban Assets Control Regulations or where the vessel has entered a port for the purpose of licensed educational activities. It stipulates that the exceptions to the 180-day rule do not in and of themselves authorise shipments to or from Cuba.

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About Michael O'Kane

Michael O'Kane

Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...

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