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The United States maintains extensive sanctions against Cuba. Whilst certain activities may be authorised under licences or exemptions, US sanctions continue to impose significant restrictions on trade, financial transactions, vessel movements and other dealings involving Cuba and Cuban interests.

In general, the United Nations, European Union and United Kingdom do not maintain comprehensive sanctions against Cuba. However, US sanctions may create risks for non-US persons and companies in certain circumstances, particularly where there is a US nexus or where US secondary sanctions considerations arise.

Members contemplating Cuba-related trade should carefully assess their potential exposure to US sanctions, including any restrictions affecting counterparties, cargoes, vessels, financing arrangements or insurance. Appropriate due diligence should be undertaken before engaging in any Cuba-related business.

This summary is intended as a high-level overview only and does not constitute legal advice. Sanctions regimes change frequently and Members should seek up-to-date advice before undertaking any trade that may give rise to sanctions concerns.

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