Effective 21 September 2015, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) made regulatory amendments allowing individuals and companies to further engage with Cuba. Of note, OFAC now authorizes certain categories of persons subject to US jurisdiction to establish a physical presence (e.g., an office) in Cuba to facilitate authorized transactions. Additionally, the BIS amended License Exception Support for the Cuban People (CSP) to authorize the export or reexport to Cuba of commodities or software that will be used by individuals or private sector entities to develop software that will improve the free flow of information or that will support certain private sector activities.
