Trump Administration Rescinds Certain Actions by Previous Administration to Ease Cuba Sanctions

Attorneys Andres Fernandez, Gabriel Caballero, Aymee Valdivia, Ronald Oleynik, Jonathan Epstein, Robert Friedman, Antonia Tzinova, Andrew McAllister, Daniel Noste and Kristen Jimenez co-authored an article for The Journal of Federal Agency Action summarizing the Trump Administration's actions regarding Cuba. Within hours of his inauguration, President Donald Trump signed an executive order rescinding nearly 80 executive actions taken by previous administrations, including orders President Joe Biden issued at the end of his term. Trump's executive order added Cuba back to the U.S. Department of the State's State Sponsor of Terrorism list and revived the Cuba Restricted List, resulting in a reinstatement of strict economic sanctions and prohibition on U.S. persons and entities from engaging in direct financial transactions with certain Cuban entities. Notably, the authors say, the executive order did not revoke the temporary suspension of Title III claims under the Helms-Burton Act, also known as the Libertad Act, though Secretary of State Marco Rubio later withdrew Biden's notice of suspension. The attorneys conclude their article by advising parties to financial transactions to exercise caution to remain in compliance with the new policies.

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