On December 17, 2014, President Obama announced a dramatic change in U.S. policy toward Cuba. The White House declared that five decades of sanctions against Cuba have “failed to accomplish our objective of empowering Cubans to build an open and democratic country,” and have failed to advance American interests. As a result, the Obama Administration will be taking steps to normalize relations with Cuba, beginning with efforts by U.S. Secretary of State John Kerry to re-establish diplomatic ties.

This new policy of engagement is expected to result in amended regulations that will allow for increased travel and flow of money, goods, and information between Cuba and the United States. Lifting the embargo currently in place against Cuba would require Congressional approval, but the Office of Foreign Assets Control (OFAC) and the Department of Commerce will make certain changes to the restrictions against Cuba in the coming weeks by amending the Cuban Assets Control Regulations (“CACR”) and the Export Administration Regulations. As OFAC stated immediately following the President’s announcement, any changes are not effective until the revised regulations are released; all current restrictions on travel and trade with Cuba remain in force until further notice. Looking ahead, however, the Administration is expected to make the following limited changes...