January, 2021 - Sanctions update: Cuba re-designated as SST

On 11th January, 2021, the US State Department re-designated Cuba as a State Sponsor of Terrorism (SST), six years after it had removed Cuba from the SST List. A few days later, the Cuban Ministry of Interior and its leader, Mr Lazaro Alberto Álvarez Casas, were designated under the Global Magnitsky sanctions, meaning that non-US persons who engage in certain transactions with those individuals, or any entity they own 50 percent or more, now face a risk of sanctions. 

As a result of its SST status, Cuba is no longer eligible to receive US foreign aid, munitions, and certain dual-use items. The practical effect of this re-listing may in reality be limited, since a number of trade embargoes already exist under the Cuban Assets Control Regulations. Certain exemptions, for example those for agricultural commodities and the “180-day rule” for foreign vessels calling at Cuba are understood to be unaffected by the latest sanctions.