Cross-Border Compliance Update

Cross-Border Compliance Update: October 2019

November 22, 2019

Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings. For more information about global compliance, visit the Foley Hoag Trade Sanctions & Export Controls Practice Group.

Included in this Issue:

  • Additional Restrictions on Exports to Cuba
  • New Sanctions on Turkey as a Result of Military Activity in Syria
  • Magnitsky Act Sanctions on South African Corruption Network
  • 28 Chinese Entities Blocked for Human Rights Violations
  • CFIUS Expansion: Non-Controlling Foreign Investments and Real Estate
  • CBP Enforces Withhold Release Orders (WROs)


Additional Restrictions on Exports to Cuba

On October 15, 2019, the Department of Commerce (DOC) amended the Export Administration Regulation (EAR) to further restrict the export and reexport of items to Cuba. The changes create a new general policy of denial for any leases of aircrafts to Cuban state-owned airlines, and clarifies that aircrafts and vessels are not eligible for the Aircraft, Vessels and Spacecraft License Exception if leased or chartered by a Cuban national.

Download the October 2019 Foley Hoag Cross-Border Compliance Update (pdf).