On December 17, 2014, President Obama announced a new U.S Policy intended to normalise relations with Cuba.
Toward implementation of that policy, the Cuban Asset Control Regulations ("CACR") were amended in January 2015.
Further amendments were recently announced by the Treasury Department's Office of Foreign Asset Control ("OFAC") and went into effect on September 21, 2015.
See the full alert by Freehill, Hogan & Mahar LLP here:
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