Search for:

On May 16, 2022, the Biden administration announced the relaxing of certain limited Cuban sanctions and other regulatory changes to expand communication, travel, and commerce between the United States and Cuba. The related fact sheet can be found here.

The US State Department outlined four changes to Cuba policy in the announcement:

  • Facilitate family reunification: The Cuban Family Reunification Parole Program will be reinstated and capacity for consular services and visa processing will continue to increase, making it possible for more Cubans to join their families in the United States via regular migration channels.
  • Expand authorized travel: Scheduled and charter flights to locations beyond Havana will again be authorized following restrictions implemented in 2019 and 2020. The Biden administration will also implement regulatory changes to reinstate group people-to-people and other categories of group educational travel, as well as certain travel related to professional meetings and professional research. Our most recent blog post about travel restrictions against Cuba is here. On June 1, 2022, the US Department of Transportation issued a corresponding Order revoking previous actions restricting certain air services between the US and Cuba, which we previously blogged about herehere, and here.
  • Support greater access to US Internet services, applications, and e-commerce platforms: There will now be support for greater access to expanded cloud technology, application programming interfaces, and e-commerce platforms. Additionally, the United States will explore new options for Internet-based activities, electronic payments, and business with independent Cuban entrepreneurs, providing entrepreneurs’ access to microfinance and training.
  • Enable increased remittance flows to the Cuban people: Remittances will flow more freely to the Cuban people as a general matter. Specifically, the current limit on family remittances of $1,000 per quarter per sender-receiver pair will be removed and donative remittances, which will support independent Cuban entrepreneurs, will be authorized. We blogged about US restrictions on remittances to Cuba here.

These changes neither modify the US embargo of Cuba, Cuba’s designation as a state sponsor of terrorism, nor the majority of the restrictions on Cuba implemented by the Trump administration, which we previously blogged about here, here, here, and here.

Pursuant to the above policy changes, on June 9, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations to implement some of the elements of the President’s foreign policy to increase support for the Cuban people. The rule authorizes group people-to-people educational travel to Cuba and removes certain restrictions on authorized academic educational activities, authorizes travel to attend or organize professional meetings or conferences in Cuba, removes the $1,000 quarterly limit on family remittances, and authorizes donative remittances to Cuba.


Bart McMillan leads the Chicago Office’s International Trade Compliance Subpractice within the North American International Commercial Practice. He advises US and non-US companies on international trade compliance matters arising under US export controls, trade sanctions, and antiboycott rules, as well as under US customs laws with respect to classification, valuation, country of origin, free trade agreements, and the protection of intellectual property at the US border. His practice also covers anti-bribery and specialized commercial compliance issues in sales and sales promotion under the US Foreign Corrupt Practices Act (FCPA), non-US anti-bribery law, and non-US commercial laws. Mr. McMillan has been practicing with Baker McKenzie for the entirety of his legal career, and during 2004 he was located in the Washington, DC office. He is a frequent speaker on international trade compliance matters at seminars, conferences, and company training events. While pursuing his J.D. at NYU School of Law, Mr. McMillan was Staff Editor (1997-98) and Associate Editor (1998-99), New York University Law Review; and he participated in a semester exchange to the Central European University (Budapest) (Legal Studies Dep’t).


Eunkyung Kim Shin regularly advises multi-national companies on complex international trade, regulatory compliance, and customs and import law related matters. She also counsels on cross-border compliance and commercial issues.


Caroline Howard is an associate in the Washington, DC office where she is a member of the International Commercial Practice Group. Her practice is focused on all aspects of international trade law, particularly compliance with US export controls, trade and economic sanctions, and US foreign investment restrictions. She represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS). Prior to joining the Firm, Caroline worked in telecommunications law. Specifically, she handled applications for international Section 214 authorizations, which included helping clients navigate Team Telecom's specific national security review for foreign participation in the US telecommunications sector.


Jennifer Trock is chair of Baker McKenzie's Global Aviation Group and North America International Commercial Practice Group. She leads the Firm's unmanned aircraft systems (UAS) focus team and is a member of the Firm's Future Mobility Taskforce. She is the immediate past chair of the ABA's Forum on Air & Space Law. Jennifer has been recognized by Chambers USA, Aviation Regulatory – National (2007-2022) and has received honors from Euromoney's Guide to the World's Leading Aviation Lawyers, Infrastructure Journal and The Washingtonian. Jennifer has also been recognized by Women in Business Law (Americas) (2021) as the Aviation Lawyer of the Year.


Alex Matthews is an associate in Baker McKenzie's International Commercial Practice Group in Washington, DC. He is a member of the Firm's Global Aviation Group and the Future Mobility and Unmanned Aircraft Systems teams. Prior to joining the Firm, Alex was an aviation and corporate associate at a top-ranked firm in Washington, DC. Previously, he served as Policy Staff for four years with the House Committee on Science, Space, and Technology.

Write A Comment