National Security Advisor Bolton Discusses New U.S. Sanctions Against Cuba

On April 17, as discussed in a prior post, the U.S. State Department announced new sanctions against Cuba. The major change was eliminating the waiver of Title III of the Helms-Burton (LIBERTAD) Act allowing U.S. litigation by U.S. owners of Cuban property that was expropriated by the Cuban government in the early years of the Cuban Revolution. This Act also allows the U.S. to deny or revoke U.S. visas to any person or corporate officer “involved in the confiscation of property or trafficking in confiscated property,” as well as their family members.

Later that same day in a Miami speech National Security Advisor John Bolton  proudly announced that “President Trump decided to END the Helms-Burton Title III Waivers, once and for all and that under Title IV of Helms-Burton no U.S. visas would be issued to “anyone who traffics in property stolen from Americans.” In addition, Bolton announced additional anti-Cuba measures.[1] As noted in a prior post, Bolton’s hostility towards Cuba is not new.

The Additional New Sanctions

The additional new sanctions announced by Bolton are the following:

  • Remittances from Cubans in the U.S. to family members on the island will be reduced by the U.S. Treasury Department to $1,000 per person [payor or payee?] per quarter. According to Bolton, the unlimited remittances permitted by the Obama Administration had allowed the Cuban government to evade U.S. sanctions and obtain access to hard currencies.
  • “Non-family travel” or “veiled tourism” to Cuba will be subject to new (and unspecified) restrictions in order to “steer American dollars away from the Cuban regime, or its military and security services, who control the tourism industry in Cuba.” (However, there still are 12 categories of permissible U.S. nationals travel to Cuba under Treasury Department regulations.)
  • The State Department will add five companies to its Cuba Restricted List, including Aerogaviota, an airline controlled by Gaviota, a group of tourism-relative companies controlled by the Cuban Armed Forces.[2]
  • The U.S. Treasury Department will adopt new regulations to “end the use of “U-turn transactions,” which allow the regime to circumvent sanctions and obtain access to hard currency and the U.S. banking system.”

Bolton’s Remarks

Bolton, once again, referred to Cuba, Venezuela and Nicaragua as the “troika of tyranny” and their leaders as “the three stooges of socialism.” They all now are “beginning to crumble” and the U.S. “looks forward to watching each corner of this sordid triangle of terror fail.”

While accusing Cuba of propping up Venezuela’s Maduro with thousands of security force members in the country, Bolton also warned “all external actors, including Russia, against deploying military assets to Venezuela to prop up the Maduro regime.”. The United States will consider “such provocative actions a threat to international peace and security in the region.” Bolton noted  that Moscow recently sent in military flights carrying 35 tons of cargo and a hundred personnel.

In short, from Bolton’s perspective, “the destinies of our nations will not be dictated by foreign powers; they will be shaped by the people who call this Hemisphere hme. Today, we proudly proclaim for all to hear: the Monroe Doctrine is alive and well.” (Emphasis added.)

In addition, Bolton had harsh words for President Obama’s efforts to normalize relations with Cuba. The National Security Advisor said, “Tragically, the Obama administration’s misguided Cuba policy provided the Cuban regime with the necessary political cover to expand its malign influence and ideological imperialism across the region.” He added, “In no uncertain terms, the Obama administration’s policies toward Cuba have enabled the Cuban colonization of Venezuela today.” The Trump Administration’s changes were designed to reverse “the disastrous Obama-era policies, and finally end the glamorization of socialism and communism.”

“To justify its policy of normalizing relations with Cuba, President Obama said Cuba (quote) ‘poses no genuine threat.’ Tell that to the American diplomats who were attacked in Havana. Tell that to the terrorized people of Venezuela. The reality is that the Obama government sought to normalize relations with a tyrannical dictatorship.”  In contrast, Bolton reminded his audience that Trump met with Cuban opposition activists like the Ladies in White and called the late Fidel Castro “a brutal dictator.”

Bolton also implicitly criticized Obama by saying “Naïve beliefs have now given way to clear-eyed common sense. We are no longer surrendering American liberty in the name of global governance. We are no longer selling out our friends to appease our adversaries. [We] are no longer sacrificing the interests of the American people to pursue idealistic fantasies—in Havana, Tehran, or anywhere else.”

After reciting the U.S. and allies’ efforts regarding Venezuela, Bolton said when Maduro falls, “we know that Cuba will be next.”

“Let me be clear: The Trump administration will NEVER, EVER abandon you,” Bolton said. “We will need your help in the days ahead. We must all reject the forces of communism and socialism in this hemisphere — and in this country.”

The Ignominious Timing and Location of the Announcement

Bolton intentionally and ignominiously chose the date and location for this announcement. Last week Bolton tweeted, “[I am] Pleased to announce that I will be joining the Bay of Pigs Veterans Association on April 17 in Miami to deliver remarks on the important steps being taken by the Administration to confront security threats related to Cuba, Venezuela, and the democratic crisis in Nicaragua.”

The date, April 17, was the 58th anniversary of the U.S. disastrous invasion of Cuba’s Bay of Pigs (Playa Girón). Recall that this failed military invasion of Cuba was undertaken by the Central Intelligence Agency (CIA)-sponsored paramilitary group Brigade 2506.  The U.S. gravely underestimated the force-power in Cuba and consequently led their troops to their own destruction. The U.S.-sponsored combatants were members of a counter-revolutionary military group (made up of mostly Cuban exiles who had traveled to the U.S. after Castro’s takeover plus some U.S. military personnel).This invading force was defeated within three days by the Cuba Revolutionary Armed Forces under the direct command of Fidel Castro.[3]

The location of Bolton’s remarks was  the Miami gathering of the Bay of Pigs Veterans Association. In his remarks Bolton paid them homage. He compared the aging Cuban Americans to “the brave men of Bunker Hill, Belleau Wood and Normandy,” and said the new measures were being undertaken to “honor your courage . . . by boldly confronting the evils of socialism and communism in the hemisphere.”

In his remarks, Bolton said, “This is just the beginning. As long as the people of Cuba, Venezuela and Nicaragua stand for freedom, the United States will stand with them. The remarkable story of Brigade 2506 helped inspire President Trump’s hard-hitting Cuba policy. During the 2016 campaign, he visited you here in Miami, he heard your heroic accounts, he saw your stirring pictures and today he is proud to stand by your side.”

“Together, we can finish what began on those beaches, on those famous days in April, 58 years ago today,” Bolton said to rousing applause from the aging brigade members who backed Trump in 2016 when he narrowly won the state.

Conclusion

Bolton’s vigorous embrace of the Monroe Doctrine is outrageous. That Doctrine is a self-proclaimed right to intervene militarily and otherwise in any other country in the Western Hemisphere when a U.S. president deems it appropriate.  From a Latin America perspective it was often seen as a U.S. license to intervene at will in other countries’ internal affairs and is contrary to international law. It, therefore, was entirely appropriate for then Secretary of State John Kerry in 2013 to state that “ the Monroe Doctrine is dead once and for all.”[4]

Also inappropriate was Bolton’s criticism of President Obama’s adoption of policies to normalize U.S.-Cuba relations. I thought and still think that was one of his administration’s greatest accomplishments.[5]

Another objection needs to be registered to Bolton’s comments about the Bay of Pigs. The U.S. financed, organized and ineptly assisted the Bay of Pigs invasion, I always have regarded it as horrible stain on U.S. relations with Cuba that repeatedly needs to be denounced.

Future posts will look at reactions to these U.S. policies from Cuba, the U.S. and other countries.

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[1] This post was updated after discovering on April 20 the text of Bolton’s speech on the website of the U.S. Embassy in Cuba.  See U.S. Embassy in Cuba, Ambassador Bolton Bay of Pigs Veterans Asociation-Brigade 2506 (April 17, 2019); Gámez Torres, Bolton coming to Miami to discuss U.S. action on Miami to discuss action on Cuba, Venezuela and Nicaragua, Miami Herald (April 12, 2019); Solomon, Reichmann & Lee (AP), Trump Cracks Down on Cuba, Nicaragua and Venezuela, Wash. Post (April 17, 2019); DeYoung, Trump administration announces new measures against Cuba, Wash. Post (April 17, 2019); Bolton announces new sanctions against Cuba, Venezuela and Nicaragua, Wash. Post  (Jan. 17. 2019 (partial video of Bolton’s remarks); Gámez Torres, U.S. restricts travel, remittances to Cuba as part of a new policy under Trump, Miami Herald (April 17, 2019).

[2] These five entities were added to the Cuba Restricted List on April 24, 2019: State Dep’t, Department of State Updates the Cuba Restricted List (April 24, 2019); State Dep’t, List of Restricted Entities and Subentities Associated with Cuba as of April 24, 2019 (April 24, 2019). See also these posts to dwkcommentarie.com: New Restrictions on U.S. Travel to Cuba and Transactions with Certain Cuban Entities (Nov. 8, 2017); More Cuban Businesses Forbidden to U.S. Visitors (Nov. 16, 2018); U.S. Authorizes U.S. Litigation Against Entities on Cuba Restricted List (Mar. 5, 2019); Cuba Modifies Its Cuba Restricted List (Mar. 13, 2019).

[3] Bay of Pigs Invasion, Wikipedia; Brigade 2506: Official Site of the Bay of Pigs Veterans Association.

[4] Johnson, Kerry Makes It Official: ‘Era of Monroe Doctrine Is Over,’ W.S.J. (Nov. 18, 2013).

[5] See posts listed in the “U.S. (Obama) & Cuba (Normalization), 2014,” “U.S. (Obama) & Cuba (Normalization), 2015,” “U.S. (Obama) & Cuba (Normalization), 2016,” and “U.S. (Obama) & Cuba (Normalization), 2017” sections of List of Posts to dwkcommentaries—Topical: Cuba.

 

U.S. Modifies Its Cuba Restricted List

On March 11, the U.S.  State Department modified its Cuba Restricted List of Cuban entities and subentries with which Americans are forbidden to have financial transactions. This modification added to this List five sub-entities owned by the Cuban military. [1]

This List, which was first promulgated in November 2017 and then previously modified in October 2018, identifies entities and subentries the U.S. has concluded “disproportionately benefit the Cuban military intelligence, and security services or personnel at the expense of the Cuban people to private enterprise.” [2]

The Department’s announcement added, “the Cuban government further consolidated the regime’s one-party dictatorship through a flawed, undemocratic constitutional referendum on February 24. We also denounce Cuba’s role in propping the failed regime of former Venezuelan president, Nicolás Maduro. Cuban military and security forces have abetted Maduro ins quest to remain in power, contributing to the Venezuelan crisis, human rights abuses against Venezuelans, and to the untold suffering of the Venezuelan people.”

Nearly simultaneously, the U.S. State Department authorized U.S. litigation against entities on this List that trafficked in property owned by U.S. nationals that was expropriated by Cuba in 1959-60. {3}

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[1] U.S. State Dep’t, State Department Updates the Cuba Restricted List (Mar. 11, 2019); U.S. State Dep’t, Cuba Restricted List 

[2] New Restrictions on U.S. Travel to Cuba and Transactions with Certain Cuban Entities, dwkcommentaries.com (Nov. 8, 2017); More Cuban Businesses Forbidden to U.S. Visitors, dwkcommentaries.com (Nov. 16, 2018). 

[3] U.S. Authorizes U.S. Litigation Against Entities on Cuba Restricted List, dwkcommentaries.com (Mar. 5, 2019); U.S. State Dep’t, Senior State Department Official On Title III of the LIBERTAD Act (Mar. 4, 2019)

U.S. House Hearing on U.S. Policy Towards Cuba  

On September 6, the U.S. House Foreign Affairs Committee’s Western Hemisphere Subcommittee held a hearing on U.S. policy on Cuba.[1]

The subcommittee heard from the  following five witnesses, the first four of whom were from the  State Department and the last (Mr. Mazanec) from the U.S. Government Accountability Office: (1) Kenneth H. Merten, Acting Principal Deputy Assistant Secretary, Bureau of Western Hemisphere Affairs; (2) Peter Bodde, Coordinator, Health Incidents Response Task Force; (3) Charles Rosenfarb, M.D., Medical Director, Bureau of Medical Services; (4) Todd Brown, Assistant Director for Countermeasures, Bureau of Diplomatic Security; and (5) Brian M. Mazanec, Ph. D.

Since the audio recording of the hearing is virtually impossible to hear, the following are the highlights of the prepared and printed statements of two of the witnesses and the brief comments from the Washington Post article.

Acting Principal Deputy Assistant Secretary Merten

Human Rights. The Department continues to monitor “human rights developments in Cuba and actively engages with members of Cuban civil society. . . . The Department and USAID also continue to administer U.S. government funded programs to promote democracy and support the critical work of human rights defenders on the island. . . . we regularly speak out against the regime for repression and abuse and raise these concerns directly with the Cuban government.

Cuban Economy. The State Department’s “Cuba Restricted List . . . identifies entities and subentities with which direct financial transactions would disproportionately benefit Cuban military, intelligence, or security services or personnel at the expense of the Cuban people or private enterprise. . . . [It seeks to ] redirect economic activity that once supported the Cuban military toward the Cuban private sector and Cuban people.”

The Department’s Cuba Internet Task force. It is charged to “develop recommendations on 1) the role of media and unregulated flow of information to Cuba and 2) expanding internet access in Cuba” and is scheduled to complete its work by June 2019.

Promoting Stability and Prosperity. The Department has “1) reviewed democracy programs in Cuba to ensure they align with the criteria set forth in the LIBERTAD Act; 2) provided a report to the President detailing the Cuban regime’s human rights abuses against the Cuban people and its lack of progress towards a “transition government” as described in the LIBERTAD Act; 3) provided a report to the President on bilateral engagement with Cuba to ensure it advances U.S. interests; 4) took a stand at the UN against Cuban anti-embargo propaganda; and 5) continues to work with the Department of Homeland Security to discourage dangerous, unlawful migration that puts Cuban and American lives at risk.”

“Health Attacks” on U.S. Personnel.  Merten reminded the subcommittee that “the Department first became aware of these health complaints and an increase in Cuban harassment in late December 2016, [bit] it was not until months later, after highly specialized medical testing was performed and analyzed by experts, that we began to understand the spectrum of severity and confirm the extent of the health effects. That confirmation indicated that these incidents went beyond routine harassment previously experienced by U.S. diplomats in Havana.”

He then stressed that  the “Department does not currently know the mechanism for the cause of the injuries, the motive behind these attacks in Cuba, when they actually commenced, or who is responsible.” (Emphasis added.)

He also emphasized that the U.S. Government was committed to long-term support for the affected personnel.

He mentioned that Secretary of State Pompeo has established an Accountability Review Board that had submitted its report on June 7 and that the Secretary has accepted all of its recommendations.

 Dr. Rosenfarb

“We’re seeing a unique syndrome. I can’t even call it a syndrome. It’s a unique constellation of symptoms and findings, but with no obvious cause,” testified Dr. Rosenfarb.

 Dr. Mazane

His prepared statement summarized the GAO’s July 30, 2018 report (released on September 6) that reviewed the State Department’s management of these health incidents and made recommendations for improvements in same.

Conclusion

 This blog previously has criticized the U.S. so-called democracy promotion activities in Cuba and the U.S. Cuba Internet Task Force because they are unilateral attempts to impose U.S. values on Cuba. Instead, this blog has advocated for the U.S. attempting to develop such programs with the cooperation of the Cuban government. This blog also has also called for the U.S. to ends its embargo of Cuba.[2]

A future post will discuss the latest developments regarding U.S. diplomats who have had medical problems arising from their being stationed in Havana.

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[1] U.S. House Rep., Foreign Affairs Comm., Western Hemisphere Subcomm., U.S. Policy Toward Cuba (Sept. 6, 2018); Kaplan & Ashenbach, Scientists and doctors zap theory that microwave weapon injured Cuban diplomats, Wash. Post (Sept. 6, 2018).

[2] See the following sections of List of Posts to dwkcommentaries—Topical: CUBA: U.S. Embargo of Cuba, Cuban Human Rights, Cuban Economy, U.S. Diplomats Medical Problems in Cuba and U.S. Cuba Internet Task Force.

 

 

Additional Reactions to New U.S. Regulations Regarding  Cuba         

As noted in a prior post, on November 8, new U.S. regulations on travel to Cuba and business with Cubans were issued while another post discussed initial reactions thereto.  Already additional reactions have surfaced: impact on what Americans drink in Cuba and the adverse impact on U.S. interests.

Americans Drinks in Cuba[1]

The new Cuba Restricted List bans U.S. businesses and individuals from doing business with the Cuba companies that produce two rum brands—Ron Varadero and Ron Caney—and three soft drinks—Tropicola Cachito, Jupiña and Nahita. That has raised concern that Americans in Cuba would have to be careful about what they drink.

Two days after the issuance of the new regulations, the U.S. Treasury issued a clarification. The List only bans direct financial transactions with the entities on the List. Therefore, says the Treasury, “Americans may still consume those soft drinks and rums” — as long as they don’t buy them directly from the companies on the List. They can buy a Tropicola from a street vendor, for example, and they won’t have to tell a bartender: ‘No Varadero or Caney rum, please.’”

But the Americans may not buy “a rum and coke at . . . one of the 83 hotels that are run by Gaviota or Habaguanex, two tourism brands controlled by the military [and, therefore, on the List]. It’s off limits for not only drinks but also lodging.”

Adverse Impact on U.S. Interests[2]

A Miami Herald journalist, Fabiola Santiago, has identified at least five ways the new regulations harm U.S. interests.

“First, by doing away with the independent people-to-people travel by Americans, . . . [the regulations] are actually helping the Cuban government control what travelers do, whom they meet, and how their perceptions of the country are shaped, thus becoming enablers of the dictatorship. Yet, tours are the mode of travel endorsed by Trump’s policy — and propagandistic historical tours are one of the activities that prove to the Treasury Department that your travel to Cuba is ‘educational.’”

Second, the new regulations put “the trips back in the hands of babysitters . . . [i.e.,] loyal government employees who shuttle around visitors. . . . Trump just expanded their ranks. Jobs!”

Third, the new regulations thereby harm “Cuba’s fledgling entrepreneurial class,” who will lose customers to the state-owned businesses.

Fourth, the new regulations do not adversely affect U.S. cruise ship operators even though their “passengers are a captive audience of government stores filled with Che Guevara paraphernalia and peddlers who offer government services to people disembarking.”

Fifth, the regulations and the Trumpian rhetoric about Cuba are helping the Russians enhance their relationship with Cuba, which includes “aggressively pursuing establishing a military base in Cuba, 90 miles from the USA.”

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[1] Whitefield, Do new rules on Cuba travel mean no rum in cocktails for American travelers? Miami Herald (Nov. 10, 2017). (I was unable to find the Treasury Department clarification on its website.)

[2] Santiago, It’s your Cuba policy, Miami republicans. You can’t blame Obama now, Miami Herald (Nov. 10, 2017)

New Restrictions on U.S. Travel to Cuba and Transactions with Certain Cuban Entities                                     

On November 8, the U.S. Treasury, Commerce and State departments released regulations imposing new restrictions on U.S. citizens travel to Cuba. Taking effect on November 9, they “are aimed at preventing U.S. trade and travelers from benefiting its military, intelligences and security arms of the Communist-ruled country.” In addition, they require U.S. travelers on “person-to-person” trips “to use a U.S.-based organization and be accompanied by a U.S. representative of the group.”[1]

This blog post will first provide a list of the Treasury Department’s 12 categories of general licenses for approved travel to Cuba, only two of which are directly affected by the new regulations. These two categories will be discussed followed by the new regulations ban on transactions with certain Cuban entities that affects all 12 categories.

Categories of Approved Travel[2]

“Travel-related transactions are permitted by [OFAC’s] general license for certain travel related to the following activities, subject to the criteria and conditions in each general license: (1) family visits; (2) official business of the U.S. government, foreign governments, and certain intergovernmental organizations; (3) journalistic activity; (4) professional research and professional meetings; (5) educational activities; (6) religious activities; (7) public performances, clinics, workshops, athletic and other competitions, and exhibitions; (8) support for the Cuban people; (9) humanitarian projects; (10) activities of private foundations or research or educational institutes; (11) exportation, importation, or transmission of information or information materials; and (12) certain authorized export transactions.”

Only the two categories in bold are affected by the new regulations—travel for “educational” reasons (organized and people-to-people) and “support for the Cuban people.”

Formal Educational Travel[3]

OFAC states, “Among other things, this general license authorizes, subject to conditions, faculty, staff, and students at U.S. academic institutions . . . to engage in certain educational activities, including study abroad programs, in Cuba, Cuban scholars to engage in certain educational activities in the United States, and certain activities to facilitate licensed educational programs. U.S. and Cuban universities may engage in academic exchanges and joint non- commercial academic research under the general license. This provision also authorizes persons subject to U.S. jurisdiction to provide standardized testing services and certain internet-based courses to Cuban nationals.

In addition, “educational exchanges, including study abroad programs, sponsored by Cuban or U.S. secondary schools involving secondary school students’ participation in a formal course of study or in a structured educational program offered by a secondary school or other academic institution, and led by a teacher or other secondary school official are authorized. Such exchanges must take place under the auspices of an organization that is a person subject to U.S. jurisdiction, and a person subject to U.S. jurisdiction who is an employee, paid consultant, agent, or other representative of the sponsoring organization (including the leading teacher or secondary school official) must accompany each group traveling to Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.565(a)(2)(vi). This authorization allows for participation of a reasonable number of adult chaperones to accompany the secondary school students to Cuba.”

“People-to-People” Educational Travel[4]

“OFAC is amending the general license for people-to-people educational activities in Cuba to remove the authorization for individual people-to-people educational travel. This general license now authorizes, subject to conditions, persons subject to U.S. jurisdiction to engage in certain educational exchanges in Cuba under the auspices of an organization that is a person subject to U.S. jurisdiction and sponsors such exchanges to promote people-to-people contact. Travelers utilizing this general license must ensure they maintain a full-time schedule of educational exchange activities intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities, and that will result in meaningful interaction between the traveler and individuals in Cuba.”

“The predominant portion of the activities must not be with a prohibited official of the Government of Cuba, as defined in 31 CFR § 515.337, or a prohibited member of the Cuban Communist Party, as defined in 31 CFR § 515.338.”

“A person subject to U.S. jurisdiction who is an employee, paid consultant, agent, or other representative of the sponsoring organization must accompany each people-to-people educational group traveling to Cuba to ensure that each traveler has a full-time schedule of educational exchange activities. Individuals traveling under the auspices of an organization that is a person subject to U.S. jurisdiction and that sponsors such exchanges to promote people-to-people contact may rely on the entity sponsoring the travel to satisfy his or her recordkeeping obligations with respect to the requirements described above. OFAC is amending this general license to exclude from the authorization direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List.”

Support for the Cuban People” Travel[5]

“This general license authorizes, subject to conditions, travel-related transactions and other transactions that are intended to provide support for the Cuban people, which include activities of recognized human rights organizations; independent organizations designed to promote a rapid, peaceful transition to democracy; and individuals and non-governmental organizations that promote independent activity intended to strengthen civil society in Cuba. OFAC is amending this general license to require that each traveler utilizing this authorization engage in a full-time schedule of activities that enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities and that result in meaningful interactions with individuals in Cuba. OFAC is also amending this general license to exclude from the authorization certain direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.574.”

“ Renting a room in a private Cuban residence (casa particular), eating at privately owned Cuban restaurants (paladares), and shopping at privately owned stores run by self-employed Cubans (cuentapropistas) are examples of authorized activities; however, in order to meet the requirement of a full-time schedule, a traveler must engage in additional authorized Support for the Cuban People activities.”

Ban on Transactions with Certain Cuban Entities[6]

The new regulations also ban U.S. travelers and businesses from transactions with “the large military-run corporations that dominate the Cuban economy. These include GAESA and CIMEX, the holding companies that control most retail business on the island; Gaviota, the largest tourism company; and Habaguanex, the firm that runs Old Havana.” The regulations include a list of forbidden hotels, including Havana’s “Manzana Kempinski, which opened with great fanfare this year as Cuba’s first hotel to meet the international five-star standard.”

This “Cuba Restricted List,” which will be maintained and updated by the State Department, has the following categories of organizations (and the number of entities in each category): Cuban Ministries (2) ; Cuban Holding Companies (including CIMEX,GAESA, Gavotte and Companies Touristic Habituate S.A.) (5) ; Hotels in Havana and Old Havana (27); Hotels in Santiago de Cuba (1); Hotels in Varadero (13); Hotels in Pinar del Rio (2); Hotels in Baracoa (7); Hotels in Cayos de Villa Clara (15); Hotels in Holguín (11); Hotels in Jardine’s del Rey (5); Hotels in Topes de Collates (3); Tourist Agencies (2); Marinas (5); Stores in Old Havana (10);  Entities Directly Serving the Defense and Security Sectors (38); Additional Subentries of CIMEX (16); Additional Subentities of GAESA (13); Additional Subentries of GAVIOTA (4); and Additional Subentries of HABAGUANEX (1).

Conclusion

All of these new regulations are meant to implement President Trump’s National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which he signed on June 16, 2017, at an event in Miami Florida.[7]

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[1] U.S. Treasury Dep’t, Treasury, Commerce, and State Implement Changes to the Cuba Sanctions Rules (Nov. 8, 2017); U.S. Treasury Dep’t (Office of Foreign Assets Control), Frequently Asked Questions Related to Cuba (updated Nov. 8, 2017); Reuters, Trump Administration Tightens Sanctions Against Cuba, N.Y. Times (Nov. 8, 2018); Assoc. Press, US Takes Steps to Make It Harder for Americans to Visit Cuba, N.Y. times (Nov. 8, 2017); DeYoung, White House implements new Cuba policy restricting travel and trade, Wash. Post (Nov. 8, 2017).

[2] U.S. Treasury Dep’t (Office of Foreign Assets Control), Frequently Asked Questions Related to Cuba (updated Nov. 8, 2017).

[3] Id.

[4] Id.

[5] Id.

[6] U.S. State Dep’t, List of Restricted Entities and Subentities Associated With Cuba as of November 9, 2017 (Nov. 8, 2017); U.S. State Dep’t, Frequently Asked Questions on the Cuba Restricted List (Nov. 8, 2017).

[7]  White House, Trump’s National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba (June 16, 2017). This Memorandum and the Miami event were discussed in a prior post.