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Cuba: AT Restrictions removed

On July 22nd, the Commerce Department published a rule implementing the May 29th decision to remove Cuba from the State Sponsor of Terrorism list. While Cuba is still subject to a statutory embargo, it is no longer subject to anti-terrorism (AT) level of controls. Due to the statutory embargo all items under the jurisdiction of the EAR (including EAR99 items) with a destination of Cuba still requires a BIS license for export, unless they are authorized by a license exception.


Cuba’s removal of their designation of a State Sponsor of Terrorism led to them being removed from Commerce’s Country Group E: 1. As such, de minimis level raises from 10% to 25% for most items sent to Cuba. Additionally, Cuba’s removal from Country Group E:1 effects provisions of license exceptions RPL, GOV, BAG, and AVS.

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