180-day waiver from US OFAC

American Club has issued  further guidance related to the US embargo of Cuba, following President Obama’s December 2014 policy direction toward that country. The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has announced further changes that take effect as of October 17th 2016 to implement the relaxation of the embargo*. American Club notes that “of particular interest to non-US vessels and shipowners (non-US Members of the Association) is the waiver of the rule prohibiting vessels from calling in the US for 180 days after vessels have called in Cuba”.

In brief, the above generally means that vessels that have delivered agricultural commodities, medicine, medical devices and purely civilian (e.g. crude oil, machinery, building products) cargoes to Cuba will no longer be prohibited from calling in the US after they have called in Cuba.

For US vessels and shipowners (US Members of the Club) that may wish to engage in services to and from Cuba, the new changes will require more detailed review and discussion.

American Club said that it was “highly recommended that Members contemplating a prospective fixture or voyage to Cuba, or which involve Cuban entities, should contact the Managers in advance to obtain their feedback as to whether such trade may prejudice the Member’s cover”. *

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20161014.aspx