OFAC amends Cuban Assets Control Regulations — bans Prohibited Accommodations List lodging and removes Cuban alcohol/tobacco import licence

Mechanism

This final rule amended four substantive areas of the CACR:

1. Prohibited Accommodations List (PAL) — new prohibition Added a ban on lodging (or paying for or reserving lodging on behalf of a third party) at any property on the Cuba Prohibited Accommodations List maintained by the State Department. The PAL identifies hotels and lodging facilities in which the Cuban military, intelligence, or security services have a substantial interest. This closed a gap under which US travellers could stay at military-controlled hotels while engaging in otherwise licensed travel.

2. Removal of accompanied-baggage alcohol and tobacco import licence Rescinded the general authorisation permitting persons subject to US jurisdiction to import Cuban-origin alcohol and tobacco products (rum, cigars) as accompanied baggage for personal, non-commercial use. The move directly targeted export earnings from Cuba's rum (Havana Club) and cigar (Cohiba, Montecristo) industries, which channel revenue through state enterprises.

3. Professional meetings and conferences — 515.564 Narrowed the general licence for professional meetings to exclude Cuba: US persons may no longer attend or organise professional meetings or conferences in Cuba under this licence without a specific OFAC licence.

4. Public performances, clinics, workshops, competitions, exhibitions — 515.575 Similarly restricted the general licence covering artistic and sports activities in Cuba. US persons may no longer participate in or organise such activities in Cuba under the general licence.

Policy context

The amendment is part of the Trump administration's maximum-pressure Cuba policy initiated by National Security Presidential Memorandum 5 (NSPM-5, June 2017), which reversed portions of the Obama-era CACR liberalisations. The September 2020 rule represents one of several incremental tightenings executed in the final months of the first Trump term, alongside a companion remittance rule (October 2020, 2020-10-27-us-ofac-cacr-cuba-restricted-list-remittances) and the State Department's expansion of the Cuba Restricted List.

Downstream implications

• US tour operators offering Cuba itineraries faced immediate exposure to the PAL prohibition.
• Rum and cigar importers lost the accompanied-baggage channel; commercial import of Cuban

products remains separately prohibited by the broader US embargo.

• Professional organisations (medical societies, bar associations, academic bodies) lost the

Cuba meeting general licence and must obtain individual OFAC licences for conference travel.

• Biden-era CACR amendments beginning June 2022 partially reversed these restrictions.

Open questions

• The PAL's exact property coverage is not specified in the rule text; the State Department

updates it periodically without formal notice-and-comment.

• OFAC FAQ guidance (FAQs 706 and 717) was issued concurrently to address questions about

whether US persons can host Cuban attendees at US-based conferences.