On January 16, 2015, the United States amended existing regulations to implement the
changes announced by President Obama on December 17, 2014, liberalizing US sanctions
and export controls targeting Cuba.1
As a result, the US Department of the Treasury’s Office
of Foreign Assets Control (OFAC) amended its economic sanctions regulations and the
US Department of Commerce’s Bureau of Industry and Security (BIS) amended its export
control regulations relating to Cuba.These amended regulations became effective on Friday,
January 16, 2015.
According to the United States, the purpose of the changes is to promote political and
economic freedom for the Cuban people by easing sanctions related to travel, remittances,
trade, banking and communications. OFAC sanctions were liberalized to authorize the
following Cuba-related activities: (i) certain financial transactions, (ii) certain types of
travel and travel services, including insurance, (iii) certain trade transactions, (iv) broader
remittances, (v) additional transactions involving telecommunications and Internet-based
services and (vi) expanded US and foreign governmental activities. US export controls were
eased to authorize the export and reexport of certain items to Cuba. Although the measures
signal the most significant change in US economic and trade policy towards Cuba to date,
the Cuba embargo remains in place and most transactions between the United States or
persons subject to the jurisdiction of the United States and Cuba continue to be prohibited.
Therefore, it is all the more important that parties contemplating activities in Cuba undertake
rigorous review of potential transactions to ensure compliance with both BIS and OFAC’s
I. Amendments to OFAC’s Cuba Sanctions Regulations
Financial Transactions Involving Cuba
Depository institutions subject to US jurisdiction are now authorized to engage in all
transactions necessary to establish and maintain correspondent accounts at a Cuban
financial institution, provided that such accounts are used only for authorized or
US Implements Measures to
Liberalize Cuba Sanctions and
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1 See December 2014 White & Case alert here.
2 A “depository institution” is an insured bank as defined in section 3 of the Federal Deposit Insurance Act; an
insured institution as defined in section 408(a) of the National Housing Act; an insured credit union as defined in
section 101 of the Federal Credit Union Act; or any other institution that is carrying on banking activities pursuant
to a charter from a federal or state banking authority.Client Alert
White & Case 2
These depository institutions may also now reject, rather than
block, funds transfers that remain prohibited originating and
terminating outside the United States so long as the originator or
beneficiary is not a person subject to US jurisdiction. If, however,
a prohibited Cuban Government Official3
or member of the Cuban
has an interest in the transfer, the transfer
should continue to be blocked.5
In addition, depository institutions
may process transfers involving an originator or beneficiary who
is not a person subject to US jurisdiction, if the transaction is
authorized for persons subject to US jurisdiction.
Banking institutions, including US-registered brokers or dealers in
securities and US-registered money transmitters may unblock any
blocked account previously blocked solely because of the interest
of one or more “Unblocked Nationals,” a new concept authorizing
dealings with Cuban nationals permanently resident outside
The regulations also relax the prohibition on establishing and
maintaining accounts in the United States or with a person subject
to US jurisdiction by, on behalf of, or for the benefit of, a Cuban
national. Specifically, depository institutions may now open and
maintain accounts for Cuban nationals present in the United States
in a non-immigrant status or pursuant to other non-immigrant
travel authorization. The account must be closed before these
individuals leave the United States at the end of their authorized
stay, otherwise the account must be blocked.
As noted below, financial institutions are also authorized to engage
in all transactions incident to the processing and payment of credit
and debit cards involving authorized travel-related transactions
Specific licenses may be issued authorizing the administration of
the estates of non-Cuban decedents who died in Cuba on or after
July 8, 1963, provided that any distribution to a blocked national of
Cuba is made by deposit in a blocked account in a domestic bank
in the name of the blocked national.
Banking institutions, including US-registered brokers or dealers in
securities and US-registered money transmitters, are authorized to
provide services in connection with the collection or forwarding of
The amount of personal periodic remittances in a three-month
period to Cuban nationals has been increased to US$2,000
Remittances by the following are now authorized:
■ Close relatives of a person subject to US jurisdiction who are
students in Cuba under the educational authorization, for the
purpose of funding such authorized activities.
■ Persons subject to US jurisdiction to individuals and independent
nongovernmental entities in Cuba, including pro-democracy
groups and civil society groups, and their members, to support:
(i) humanitarian projects7
in or related to Cuba that are designed
to directly benefit the Cuban people; (ii) the Cuban people
through activities of recognized human rights organizations,
independent organizations designed to promote a rapid,
peaceful transition to democracy, and activities of individuals
and non-governmental organizations that promote independent
activity intended to strengthen civil society in Cuba; and (iii) the
development of private businesses, including small farms.
3 Defined as Ministers and Vice-ministers, members of the Council of State and the Council of Ministers; members and employees of the National Assembly of People’s Power;
members of any provincial assembly; local sector chiefs of the Committees for the Defense of the Revolution; Director Generals and sub-Director Generals and higher of all
Cuban ministries and state agencies; employees of the Ministry of the Interior (MININT); employees of the Ministry of Defense (MINFAR); secretaries and first secretaries of
the Confederation of Labor of Cuba (CTC) and its component unions; chief editors, editors, and deputy editors of Cuban state-run media organizations and programs, including
newspapers, television and radio; and members and employees of the Supreme Court (Tribuno Supremo Nacional).
4 Defined as members of the Politburo, the Central Committee, Department Heads of the Central Committee, employees of the Central Committee and secretaries and first
secretaries of the provincial Party central committees.
5 This authorization does not relieve blocking obligations under other sanctions programs and regulations including OFAC’s List of Specially Designated Nationals and Blocked
Persons (SDN List).
6 Unblocked Nationals are defined as:
• Individual nationals of Cuba who have taken up residence in the United States and are a US citizen, permanent resident, or have applied to become a lawful permanent
resident and have an adjustment of status application pending, or are lawfully present and intending to lawfully remain in the United States on a permanent basis.
Such persons cannot be a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party.
• Individual nationals of Cuba who have taken up permanent residence in a third country, provided certain required documentation is obtained demonstrating permanent
resident status. Such persons cannot be a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party.
• Entities that otherwise would be a national of Cuba solely because of the interest of one or more individuals who would be considered unblocked nationals.
Unblocked Nationals remain unblocked unless and until the individual becomes domiciled in or a permanent resident of Cuba.
7 The following projects are authorized: medical and health-related projects; construction projects intended to benefit legitimately independent civil society groups;
environmental projects; projects involving formal or non-formal educational training, within Cuba or off-island, on the following topics: entrepreneurship and business, civil
education, journalism, advocacy and organizing, adult literacy or vocational skills; community-based grassroots projects; projects suitable to the development of small-scale
private enterprise; projects that are related to agricultural and rural development that promote independent activity; microfinancing projects (except for loans, extensions of
credit, or other financing prohibited under the regulations); and projects to meet basic human needs.Client Alert
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Specific licenses may be issued on a case-by-case basis to
■ By persons subject to US jurisdiction to a person in Cuba,
directly or indirectly, for transactions to facilitate non-immigrant
travel by an individual in Cuba to the United States under
circumstances where humanitarian need is demonstrated,
including illness or other medical emergency.
■ From a blocked account to a Cuban national in excess
The amendments related to telecommunications are intended
to provide efficient and adequate telecommunications
services between the United States and Cuba. The following
transactions, including payments, relating to the provision
of telecommunications services are authorized, subject to a
reporting requirement to OFAC:
■ Transactions incident to the provision of telecommunications
services9 related to the transmission or the receipt of
telecommunications involving Cuba, including the entry into
and performance under roaming service agreements with
telecommunications services providers in Cuba, by persons
subject to US jurisdiction.
■ Contracts with telecommunications service providers, or
particular individuals in Cuba, for telecommunications services
provided to particular individuals in Cuba, provided that such
individuals in Cuba are not prohibited officials of the Government
of Cuba, or prohibited members of the Cuban Communist Party.
■ Transactions incident to the establishment of facilities,
including fiber-optic cable and satellite facilities, to provide
telecommunications services linking the United States or
third countries and Cuba, including facilities to provide
telecommunications services in Cuba.
2. Internet-Based Services
The changes related to Internet-based services authorize persons
subject to US jurisdiction to provide additional services incident to
Internet-based communications and related to certain authorized
exportations and reexportations of communications items. The
new regulations broadly authorize the exportation or reexportation,
directly or indirectly, from the United States or by a person subject
to US jurisdiction to Cuba of:
■ Services incident to the exchange of communications over the
internet, such as instant messaging, chat and email, social
networking, sharing of photos and movies, web browsing,
blogging, web hosting (provided that it is not for the promotion
of tourism) and domain name registration services.10
■ Services, including software design, business consulting and
information technology management services (including cloud
storage), that are related to the following items, or of services
to install, repair (including repair training), or replace such items:
— Items subject to the Export Administration Regulations (EAR)
exported or reexported to Cuba under License Exception
Consumer Communications Devices (CCD).
— Items of foreign origin or located outside the United States
that are exported, reexported, or provided, directly or
indirectly, by a person subject to US jurisdiction to Cuba
pursuant to a specific license, items that are of a type
described in License Exception CCD, provided that the items
would be designated EAR99 or would meet the criteria for
classification under the relevant Export Classification Control
Number (ECCN) specified in License Exception CCD if they
were subject to the EAR.
— “Publicly available” software not subject to the EAR that is
exported, reexported or provided, directly or indirectly, by a
person subject to US jurisdiction to Cuba; software that is of
a type described in License Exception CCD.
Additionally, the importation into the United States of items
described above by an individual entering the United States,
directly or indirectly, from Cuba is also authorized.
8 OFAC also is expanding authorizations for the operation of news bureaus, permitting all transactions necessary for the establishment and operation of news bureaus in Cuba
whose primary purpose is the gathering and dissemination of news to the general public. This includes the hiring and employment of Cuban nationals in Cuba to provide
reporting services or other services related to the gathering and dissemination of news.
9 “Telecommunications services” includes data, telephone, telegraph, internet connectivity, radio, television, news wire feeds, and similar services, regardless of the medium
of transmission, including transmissions by satellite.
10 These services may be provided to a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party, or to organizations administered
or controlled by the Government of Cuba or the Cuban Communist Party, provided they are widely available to the public at no cost to the user. This also pertains to services
related to items subject to the EAR exported or reexported to Cuba under License Exception CCD.Client Alert
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Unless specifically stated, these authorizations do not include:
■ The direct or indirect exportation or reexportation of services
with knowledge or reason to know that such services are
intended for a prohibited official of the Government of Cuba,
or a prohibited member of the Cuban Communist Party, or to
organizations administered or controlled by the Government of
Cuba or the Cuban Communist Party.
■ The direct or indirect exportation of any items to Cuba.
Specific licenses may be issued on a case-by-case basis for the
exportation of other Internet-based services.
The regulations now authorize the provision of health insurance,
life insurance, and travel insurance–related services to authorized
travelers, as well as the receipt of emergency medical services
and the making of payments related to such services.
Additionally, persons subject to US jurisdiction are authorized to
issue or provide coverage for global health, life, or travel insurance
policies for individuals ordinarily resident in a country outside
of Cuba who travel to or within Cuba. Persons subject to US
jurisdiction are authorized to service those policies and pay claims
arising from events that occurred while the individual was traveling
in, or to or from, Cuba.
Relaxation of Impediments to Trade
In the context of certain authorized transactions, such as those
involving agricultural goods, OFAC has revised the definition of
“cash in advance” from “cash before shipment” to “payment
before the transfer of title to, and control of, the exported items
to the Cuban purchaser.” Previously, payment was required
“before shipment,” limiting the trade finance possibilities and
imposing increased costs on parties engaging in such transactions.
The change is intended to allow expanded financing options for
authorized exports to Cuba. Financing must still be provided by
a banking institution located in a third country that is not a US
citizen, a US permanent resident alien, or an entity organized
under the laws of the United States or any jurisdiction within the
United States (including any foreign branch of such an entity) or a
designated party. However, such financing may be confirmed or
advised by a US banking institution.
In the past, another impediment to trade-related transactions with
Cuba was a prohibition on the entry of vessels into US ports that
had recently visited a Cuban port. This made chartering vessels for
Cuba trade difficult, as additional time had to be built into a voyage
to comply with the prohibition on vessel entry. Under the amended
regulations, this prohibition on entry would no longer apply to a
■ Is engaging or has engaged in certain authorized or exempt
trade with Cuba
■ Is engaging or has engaged in the exportation or re-exportation to
Cuba from a third country of agricultural commodities, medicine,
or medical devices that would be considered EAR99 under the
EAR if they were located in the United States or
■ Has entered a port or place in Cuba while carrying
students, faculty, and staff authorized to travel to Cuba
under the regulations
Additionally, the provision of goods and services ordinarily incident
and necessary to the personal maintenance of Cuban nationals
who are prohibited from disembarking from vessels in US ports
Persons subject to US jurisdiction may also engage in all
transactions, including payments, necessary to import
certain goods and services produced by independent Cuban
entrepreneurs as set forth on the State Department’s
Section 515.582 List.11
In third countries, persons subject to US jurisdiction are authorized
to sponsor, provide services in connection with, and participate
in conferences or other similar events in a third country that are
attended by Cuban nationals, provided that the conference or other
similar event does not relate to tourism in Cuba.
Any US-owned or US-controlled partnership, association,
corporation, or other organization in a third country is authorized
to provide goods and services to a Cuban national who is an
individual located outside of Cuba, provided that the transaction
does not involve a commercial exportation, directly or indirectly, of
goods or services to or from Cuba.
Travel to Cuba
OFAC has generally authorized 12 categories of travel, which
previously required specific licensing.12 Tourism travel to Cuba
11 As of the date of publication, this list has not yet been generated, but will be available at http://www.state.gov/e/eb/tfs/spi/.
12 Family visits; Official business of the US government, foreign governments, and certain intergovernmental organizations; Journalistic activity; Professional research and
professional meetings; Educational activities; Religious activities; Public performances, clinics, workshops, athletic and other competitions, and exhibitions; Support for the
Cuban people; Humanitarian projects; Activities of private foundations or research or educational institutes; Exportation, importation or transmission of information or
informational materials; Certain export transactions that may be considered for authorization under existing regulations and guidelines.Client Alert
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OFAC has eliminated the per diem limit on spending ordinarily
incident to authorized travel within Cuba and the purchase of
goods for personal consumption in Cuba is permitted. Authorized
travelers may also carry US$10,000 in remittances to Cuba.
They may import no more than US$400 worth of goods from
Cuba, including up to US$100 in alcohol or tobacco products
combined. Non-US persons arriving in the United States on a
trip that included Cuba may import up to US$100 of alcohol or
tobacco products purchased or otherwise acquired in Cuba as
accompanied baggage, for personal use only.
US credit and debit cards13 may now be used in Cuba for
authorized travel-related transactions. Persons subject to
US jurisdiction may rely on the traveler to comply with this
authorization, provided that such persons do not know or have
reason to know that a transaction is unauthorized. US financial
institutions are accordingly authorized to enroll merchants and
process such transactions.
Persons subject to US jurisdiction, including travel agents and
airlines, are authorized to provide certain travel and carrier services
by aircraft to, from, or within Cuba in connection with authorized
travel or transportation to Cuba of persons, baggage, or cargo,
without a specific license. Scheduled flights to Cuba are now
permitted; however, the other federal agencies, including the US
Department of Transportation, will need to establish procedures
for restoration of scheduled services. Payments and related
transactions for certain overflights of Cuba by US aircraft are
also now authorized without a specific license.
OFAC is expanding an existing authorization covering all Cubarelated
transactions by employees, grantees, and contractors
of the US Government, foreign governments, and certain
international organizations in their official capacities.
Specifically, depository institutions are authorized to process funds
transfers for the operating expenses or other official business in
Cuba of third-country official missions or any intergovernmental
organization in which the United States is a member or holds
observer status, as well as processing funds transfers and
maintaining accounts for the personal expenditures of the
employees, grantees, and contractors, or persons who share
a common dwelling as a family member of such employees,
grantees, and contractors, of third-country official missions or any
intergovernmental organization in which the United States is a
member or holds observer status in Cuba.
Additionally, OFAC has authorized the provision of goods and
services (and corresponding payment) with Cuban official missions
and their employees14 in the United States provided:
■ The goods or services are for the conduct of the official
business of the missions, or for personal use of the employees,
or persons who share a common dwelling as a family member
of such an employee of the missions, and are not for resale.
■ The transaction does not involve the purchase, sale, financing
or refinancing of real property.
■ The transaction is not otherwise prohibited by law.
Depository institutions are authorized to operate accounts for, or
extend credit to, the official missions of the Government of Cuba
to the United States, and the official missions of the Government
of Cuba to international organizations in the United States, and
employees of such organizations. Reports to OFAC are required
under this authorization.
II. Cuba Export Control Restrictions:
Amendments to BIS Regulations:
Corresponding liberalizations have been made to US export
controls through amendments to EAR. These changes
include a new License Exception Support for the Cuban
People (SCP), expansions to License Exception Consumer
Communications Devices (CCD) and License Exception Gift
Parcels and Humanitarian Donations (GFT), and a favorable
licensing policy for exports and reexports of items necessary for
License Exception Support for the Cuban People (SCP)
(Section 740.21 of the EAR)
The newly-created License Exception SCP authorizes a number of
different exports and reexports without a license of items that are
either classified EAR99 or controlled on the Commerce Control
List (CCL) only for anti-terrorism purposes and meet the criteria
For the items listed below, Cuban government import agencies
and other government-owned, operated or controlled companies
and corporations may act as consignees to receive and effect
delivery of eligible items to the private sector. With the exception
of telecommunications authorizations, Cuban government-owned,
operated or controlled companies and corporations may not be
end users of the items.
13 In addition to stored value cards, checks, drafts, travelers’ checks, and similar instruments.
14 Including persons who share a common dwelling as a family member of such an employee.Client Alert
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1. Private Sector Tools and Equipment
This License Exception authorizes the export or reexport of
commercially sold or donated items within one or more of the
■ Building materials equipment and tools for use by the
private sector15 to construct or renovate privately owned
buildings, including privately owned residences, businesses,
places of worship and buildings for private sector social or
■ Tools and equipment for private sector agricultural activity
■ Tools, equipment, supplies and instruments for use by private
According to the regulations, this includes goods for use by
private sector entrepreneurs such as auto mechanics, barbers
and hairstylists, and restaurateurs.
BIS guidance also states that instruction manuals or other
information on how to assemble and use authorized tools and
equipment are likely not subject to the regulations, and therefore
likely may accompany any exports of equipment or tools.
2. Items for use in Scientific, Archeological, Cultural,
Ecological, Educational, Historic Preservation or
This License Exception authorizes the export or reexport of
donated items for use in scientific, archaeological, cultural,
ecological, educational, historic preservation, or sporting
activities, or the temporary export of items by persons departing
the United States for use in scientific, archeological, cultural,
ecological, educational, historic preservation, or sporting
activities, or for their use in their professional research.
In each case, such items (or activities) may not relate to
the development, production, use, operation, installation,
maintenance, repair, overhaul or refurbishing of any item
enumerated or otherwise described on the US Munitions List
(USML) or CCL unless only controlled for anti-terrorism purposes.
For the temporary export provision to apply, the items must
be directly related to the traveler’s profession, professional
background or area of expertise, including area of graduatelevel
full-time study. The items must also be returned to the
United States within two years unless consumed in Cuba or
specifically authorized by BIS.
3. Items for Individuals and Organizations in Support of
Activity Intended to Strengthen Civil Society
License Exception SCP further authorizes the export and reexport
to Cuba of certain items to human rights organizations, individuals
or non-governmental organizations that promote independent
activity intended to strengthen civil society.
4. Items in Support of the Free Flow of Information
Finally, License Exception SCP authorizes the export or reexport
to Cuba of certain items intended to improve the free flow of
information to, from and among the Cuban people:
■ Items, either sold or donated, for telecommunications, including
access to the Internet, use of Internet services, infrastructure
creation and upgrades.
■ Certain items for use by news media personnel engaged in the
gathering and dissemination of news to the general public.
News media personnel are defined to be:
— Regularly employed as journalists by a news
— Regularly employed as supporting broadcast or
— Freelance journalists with a record of previous journalistic
experience working on a freelance journalistic project
— Broadcast or technical personnel with a record of previous
broadcast or technical experience who are supporting a
freelance journalist working on a freelance journalistic project
■ Items for use by US news bureaus engaged in the gathering and
dissemination of news to the general public.
With respect to telecommunications exports, BIS guidance
confirms that certain items may be sold to Cuban governmentowned,
operated or controlled companies and corporations for
telecommunications infrastructure creation and upgrades.
Revision of License Exception Consumer Communications
Devices (CCD) (Section 740.19 of the EAR)
License Exception CCD, first issued in 2009, authorized the
export and reexport of certain consumer communications devices
that were donated to Cuba. This revision removes the donation
requirement and authorizes such exports on a commercial basis.
15 BIS guidance states that the private sector in Cuba encompasses economic activity generated by private individuals and groups as enterprises for profit and also that which is
generated by non-profit organizations and charities. Companies and corporations that are government-owned, operated or controlled are not considered private sector.Client Alert
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Importantly, License Exception CCD does not authorize US-owned
or US–controlled entities in third countries to engage in reexports
of foreign-produced commodities to Cuba for which no license
would be issued by OFAC.
Specifically, License Exception CCD authorizes the export and
reexport of consumer communications devices (commodities
such as computers, communications equipment and related
items, including personal computers, mobile phones, televisions,
radios and digital cameras) that are widely available for retail
purchase and that are commonly used to exchange information
and facilitate interpersonal communications, as well as certain
telecommunications and information security–related software.
The items eligible for export under this authorization have been
updated and now include the following:
Eligible end users include independent non-governmental
organizations and individuals other than specified Cuban
Government and Cuban Communist Party Officials. However,
consumer communications devices such as mobile phones,
computers and related hardware and software may be sold to
Cuban government-owned, operated or controlled companies and
corporations if they are intended for resale to the Cuban people.
The following are not eligible to receive exports under this
■ The Cuban Government, Cuban Communist Party or any
organizations they administer or control
■ Cuban Government Officials16
■ Cuban Communist Party Officials17
Expansion of License Exception Gift Parcels and
Humanitarian Donations (GFT) (Section 740.12 of the EAR)
The expansion of License Exception GFT now authorizes the
export and reexport of multiple gift parcels in a single shipment,
instead of only authorizing one parcel per shipment.
New Licensing Policy for Environmental Protection,
Including Renewable Energy (Section 746.2 of the EAR)
BIS has implemented a general policy of approval for applications to
export or reexport items necessary for the environmental protection
of US and international air quality, waters, and coastlines (including
items related to renewable energy or energy efficiency).
As noted, while covering a broad range of topics, the amended
regulations narrowly limit newly authorized transactions. Further,
transactions may be subject to regulation by both OFAC and BIS.
Companies doing business or wishing to do business with Cuba
therefore should monitor these developments closely to ensure
compliance. The White House has emphasized that “Persons must
comply with all provisions of the revised regulations; violations of
the terms and conditions are enforceable under US law.” Penalties
for noncompliance can be severe.
1. Consumer computers EAR99, 5A992.c,
2. Consumer disk drives and solid state
3. Input/output control units (other than industrial
controllers designed for chemical processing)
4. Graphics accelerators and
5. Monitors EAR99, 5A992.c
6. Printers EAR99, 5A992.c
7. Modems EAR99,
8. Network access controllers and
communications channel controllers
9. Keyboards, mice and similar devices EAR99
10. Mobile phones, including cellular and satellite
telephones, personal digital assistants, and
subscriber information module (SIM) cards
and similar devices
11. Memory devices EAR99, 5A992.c
12. Consumer “information security” equipment,
“software” (except “encryption source code”)
13. Digital cameras and memory cards EAR99,5A992
14. Television and radio receivers EAR99, 5A992
15. Recording devices EAR99, 5A992
16. Batteries, chargers, carrying cases and
accessories for the equipment described
in this list
17. Consumer “software” (except “encryption
source code”) used for equipment described
in 1 – 16 above
16 Including Ministers and Vice-ministers; members of the Council of State;
members of the Council of Ministers; members and employees of the National
Assembly of People’s Power; members of any provincial assembly; local sector
chiefs of the Committees for the Defense of the Revolution; Director Generals
and sub-Director Generals and higher of all Cuban ministries and state agencies;
employees of the Ministry of the Interior (MININT); employees of the Ministry of
Defense (MINFAR); secretaries and first secretaries of the Confederation of Labor
of Cuba (CTC) and its component unions; chief editors, editors and deputy editors
of Cuban state-run media organizations and programs, including newspapers,
television, and radio; or members and employees of the Supreme Court (Tribuno
17 Including Members of the Politburo; the Central Committee; Department Heads
of the Central Committee; employees of the Central Committee; and the
secretaries and first secretaries of provincial Party central committees.Client Alert
This Client Alert is provided for your
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