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On September 21, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (ā€œOFACā€) and the U.S. Commerce Department’s Bureau of Industry and Security (ā€œBISā€) introduced a second round of amendments (the ā€œSeptember Amendmentsā€) to the Cuban Assets Control Regulations (ā€œCACRā€) and the Export Administration Regulations (ā€œEARā€) in a continuing…