On May 29, 2015, the United States formally rescinded Cuba's designation as a State Sponsor of Terrorism. This is another step in the improving relations between the United States and Cuba, potentially paving the path towards further liberalization of restrictions on interactions with Cuba.
In December 2014, President Obama ordered a review of Cuba's designation as a State Sponsor of Terrorism. The State Department concluded the review on April 8, 2015, with a recommendation that Cuba no longer be designated as a State Sponsor of Terrorism.
Removal from the list of State Sponsors of Terrorism requires notification to Congress 45 days in advance of removal of the designation. The President submitted this notification on April 14, 2015, which consisted of a report and certification to Congress that Cuba has not provided any support for international terrorism during the previous six months in addition to assurances from Cuba that it will not support acts of international terrorism in the future. The pre-notification period expired after 45 days, thus permitting the removal of the designation, effective May 29, 2015.
Despite this removal, most restrictions against activities involving Cuba remain in place pursuant to other legislation. Although this may signal the possibility of future liberalization of the restrictions, no significant changes have occurred at this time as a result of the removal of the designation. Our reports on previous liberalization of the Cuba measures are available here and here. Companies should monitor closely any developments with respect to Cuba to ensure compliance. Penalties for noncompliance are severe.