Author: Poblete Tamargo LLP

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US Government Issues Cuba Travel Advisory

Poblete Tamargo analysts have noted an increase number of U.S. and foreign-based companies offering Cuba travel packages to persons living in the United States. We believe that some of these companies are making offers that appear to be outside the bounds set by the U.S. government for sponsored and educational travel to the island. In the process, they may be exposing customers to legal liablity. 

Tourism and tourism-like travel is not allowed for any persons travelling to Cuba, including U.S. persons with family on the island. People who are authorized to travel to Cuba remain subject to daily spending limits and are prohibited from bringing any Cuban “souvenirs” or other goods into the United States, with the exception of information and informational materials.

Civil and criminal penalties remain in place for violations of the Cuba sanctions regulations. 

The OFAC Advisory is available for review, here. 

 

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U.S. Updates Export Control Entity List

The Entity List provides notice to the public that certain exports, reexports, and transfers (in-country) to entities identified on the Entity List require a license from BIS and that the availability of license exceptions in such transactions is limited.

The Federal Register notice on this update is available here.

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Obama Administration Announces New Strategy to Combat Transnational Crime

Of particular interest, an Executive Order will establish a new economic sanctions program to “block the property of and prohibit transactions with significant transnational criminal networks that threaten national security, foreign policy, or economic interests.”

This announcement will be of interest to companies engaged in international trade as we as financial institutions located throughout the world. There is also a Foreign Corrupt Practices Act component. The White House report is available for download here.

We will be sending to our clients a detailed analysis of this new strategy. It will summarize how it will impact their compliance and other business considerations. Please contact us if you are interested in learning more about this or how we can assist your company with your federal regulatory or business needs.

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Poblete Tamargo Attorney Testified Before a Congressional Committee Today

IMG_0379B(Washington, DC) Poblete Tamargo Attorney Mauricio Tamargo testified this afternoon before the U.S. Congress, Natural Resources Subcommittee on Fisheries, Wildlife, Oceans and Insular Affairs in support of in support of H.R. 44, the Guam World War II Loyalty Recognition Act. 

Tamargo was asked by Congress to explain the work and findings of the Review Commission and justify the necessity of funding these aging claims. Tamargo outlined the Review Commission’s findings stressing the U.S.’s moral obligation to satisfy the outstanding claims of the U.S. nationals in Guam for the atrocities committed against them by virtue of their solidarity with the U.S. in World War II saying “the payment of these awards fulfills a moral obligation”.

Tamargo also clarified that funding for these claims could be derived from monies confiscated from Japan, rather than U.S. dollars as “the funds are, in some sense, traceable to the funds derived from the postwar liquidation of the Japanese and German assets frozen at the beginning of World War II”. 

In his former capacity as Chairman of the Foreign Claims Settlement Commission, at the Department of Justice, Tamargo also Chaired the Guam War Claims Review Commission (‘Review Commission”), in 2003. For more information and to view the archived hearing webcast, please visit the Subcommittee on Fisheries, Wildlife, Oceans and Insular Affairs website.