Trump Reverses Course on Cuba – What it Means

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Friday, July 7, 2017
Farhad Mirzadeh and Bruce Zagaris

President Trump has announced a reversal of American policy toward Cuba after revealing his Administration’s plans to partially reinstate sanctions on the coastal country.  The Trump administration’s harsh rhetoric obscures the more modest policy changes, but how the President’s directives get implemented will ultimately determine how serious the new Administration is about gutting the Obama administration’s attempted détente.  For any changes to take place, the Bureau of Industry and Security under the Department of Commerce will have to amend the Export Administration Regulations (“EAR”), and OFAC will have to amend the Cuban Assets Control Regulation (“CACR”). Under President Trump’s directive, the two agencies have 30 days to write new regulations to align their policies with the President’s proclamations.