On 11 January 2021, the Trump Administration re-designated Cuba as a state sponsor of terrorism (“SST”). Cuba had that designation removed in 2015 by the Obama Administration. The list to which Cuba is being re-added also includes Syria, Iran and North Korea. To date, there has been no indication as to the Biden Administration’s response to this action.
Countries designated as state sponsors of terrorism by the US Department of State have been determined by the Secretary of State to have repeatedly provided support for acts of international terrorism. Countries receive this designation pursuant to three laws, namely the:
Once designated, countries from this list are subject to four main categories of sanctions. These include:
Cuba’s SST designation may lead to increased scrutiny for US listed companies engaging with Cuban companies. For instance, if deals have not been previously disclosed in a company’s regular filings, then the Security and Exchange Commission’s Office of Global Security Risk may request information from US listed companies regarding Cuba transactions.
Deloitte’s Global Trade Advisory specialists are part of a global network of professionals who can provide specialised assistance to companies in global trade matters. Our professionals can help companies seeking to manage the impacts and potential impacts of the developments described above by:
Meng Yew Wong