Tuesday, July 21, 2015


Commerce Department Implements Removal of State Sponsor of Terrorism Designation for Cuba


WASHINGTON – The United States Department of Commerce Bureau of Industry and Security (BIS) today implemented (link) the Secretary of State’s removal of Cuba from the list of State Sponsors of Terrorism. The revisions, on public display in today’s Federal Register, eliminate references in the Export Administration Regulations (EAR) to Cuba as a State Sponsor of Terrorism.

Changes resulting from the removal of the State Sponsor of Terrorism designation include permitting the reexport to Cuba of foreign-made products with up to 25% U.S.-origin content, (up from the current level of 10%), and also generally allowing the export of replacement parts for items legally exported to Cuba.

In addition, general aviation, such as corporate jets, may now use license exceptions for trips to Cuba. License exceptions allow for exports or reexports under certain conditions that could otherwise require a license under the EAR. Previously, only charter flights were eligible for this license exception.

Consistent with the comprehensive embargo on trade with Cuba, however, a license will still be required to export or reexport to Cuba any item subject to EAR unless a license exception is available.

BIS has posted guidance to help exporters understand the updated Regulations. (link)

BIS controls exports and reexports of commodities, technology, and software to support national security and foreign policy, including nuclear, chemical and biological weapons, and missile non-proliferation, human rights, regional stability, and curbing terrorism. Criminal penalties and administrative sanctions can be imposed for violations of the EAR. For more information, please visit


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