On November 14, 2025, the White House released a Fact Sheet providing details on The Korea Strategic Trade and Investment deal first announced in July 2025.  The Fact Sheet provides an overview on the following issues:

  • Rebuilding and Expanding Critical Industries – South Korea will make investments into various sectors of the U.S. economy, including, but not limited to, shipbuilding, energy, semiconductors, pharmaceuticals, critical minerals, and artificial intelligence/quantum computing.
  • Section 232 Tariffs – The United States will reduce its Section 232 sectoral tariffs on automobiles, auto parts, timber, lumber, and wood derivatives of South Korea to 15 percent. For any Section 232 tariffs imposed on pharmaceuticals, the United States will apply to originating goods of South Korea a tariff rate no greater than 15 percent.  For any Section 232 tariffs imposed on semiconductors and manufacturing equipment, the United States will provide terms for such Section 232 tariffs on South Korea that are no less favorable than terms that may be offered in a future agreement covering a volume of semiconductor trade at least as large as South Korea’s, as determined by the United States.
  • Reciprocal Tariffs – The United States will remove the supplemental reciprocal tariffs for certain products identified on a list of Potential Tariff Adjustments for Aligned Partners, such as generic pharmaceuticals, generic pharmaceutical ingredients, generic pharmaceutical chemical precursors, and certain natural resources unavailable in the United States. The United States will also remove tariffs on certain aircraft and parts from South Korea.
  • Reciprocal Trade – South Korea will address non-tariff barriers and memorialize commitments and a plan of action to promote reciprocal trade. This will include, but not be limited to, the following: reducing caps on U.S.-built motor vehicles without requiring further modifications; addressing non-tariff barriers in trade in food and agricultural products; removing barriers concerning digital services; protecting intellectual property rights; and ensuring protection of international labor rights.
  • Supply Chain Protections – the Fact Sheet also notes that both countries will work to strengthen economic and national security alignment to preserve competitiveness and maintain secure supply chains. This area of cooperation will include combating duty evasion, enhancing inbound investment and outbound investment regulations, and ensuring that international procurement obligations provide a benefit to those countries that have taken on the same commitments.

The Fact Sheet also provides additional information regarding modernizing the U.S.–South Korea military alliance as well as coordination on issues impacting the Korean peninsula and the larger Indo-Pacific region.  Since the presidents of the two countries met on October 29, 2025, no substantive text of any formal trade agreement or deal has been released.

On July 15, 2025, the Office of the United States Trade Representative (USTR), at the direction of President Donald Trump, initiated an investigation of Brazil under Section 301 of the Trade Act of 1974. The investigation will seek to determine whether acts, policies, and practices of the government of Brazil related to digital trade and electronic payment services; unfair, preferential tariffs; anti-corruption interference; intellectual property protection; ethanol market access; and illegal deforestation are unreasonable or discriminatory and burden or restrict U.S. commerce. Ambassador Jamieson Greer stated, “USTR has detailed Brazil’s unfair trade practices that restrict the ability of U.S. exporters to access its market for decades in the annual National Trade Estimate (NTE) Report. After consulting with other government agencies, cleared advisers, and Congress, I have determined that Brazil’s tariff and non-tariff barriers merit a thorough investigation, and potentially, responsive action.” The USTR is requesting consultations with the government of Brazil, as required under the Trade Act of 1974. It is also accepting written comments from interested parties until August 18, 2025; and a public hearing will be held beginning on September 3, 2025.

As detailed in the Federal Register notice, the investigation will cover numerous trading practices, including:

  1. Digital trade and electronic payment services: Brazil may undermine the competitiveness of U.S. companies engaged in these sectors by, for example, censoring U.S. social media companies and undermining the competitiveness of U.S. companies engaged in digital trade and electronic payment services;
  2. Unfair, preferential tariffs: Brazil may offer lower, preferential tariff rates to certain large trading partners in specific sectors;
  3. Anti-corruption enforcement: Brazil’s efforts to enforce anti-corruption and transparency measures may have weakened in certain areas;
  4. Intellectual property protection: Brazil may deny adequate and effective protection and enforcement of intellectual property rights, including importation, distribution, sale, and use of counterfeit goods, modified gaming consoles, illicit streaming devices, and other circumvention devices;
  5. Ethanol market access: Brazil has allegedly “abandoned” the reciprocal and virtually duty-free treatment for U.S. ethanol and instead now applies a substantially higher tariff and use of a tariff-rate quota on U.S. ethanol exports; and
  6. Illegal deforestation: Brazil may lack effective enforcement of laws and regulations designed to stop illegal deforestation, and is allowing illegal timber harvesting and agricultural production on such lands.

Pursuant to Section 304 of the Trade Act, the USTR must determine whether these acts, policies, or practices are actionable under Section 301. If that determination is affirmative, the USTR must determine whether action is appropriate, and, if so, what action to take. 

The USTR is seeking written comments from any interested party on any issued covered by the investigation. The Federal Register notice does identify particular issues for each of the previously listed trading practices where the USTR seeks to determine if Brazil’s acts, policies, or practices discriminate against or unfairly disadvantage U.S. companies. To be assured of consideration, the USTR must receive written comments by 11:59 p.m. EDT on August 18, 2025. USTR Docket No. USTR-2025-0043 has been established for this investigation and will be available here beginning on July 17, 2025.

The USTR will hold a public hearing on September 3, 2025, beginning at 10 a.m. EDT in the main hearing room of the U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436. If necessary, the hearing may continue the next business day. A request to appear at the hearing, along with a summary of the testimony, must be submitted to the USTR by August 18, 2025. A docket for requests to appear at the hearing will be available here

On July 1, 2025, the Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of unmanned aircraft systems (UAS) and their parts and components. The Department’s Bureau of Industry and Security (BIS) subsequently issued a Notice of Request for Public Comments indicating that interested parties may submit written comments, data or other information pertinent to the investigation no later than August 6, 2025.

BIS is particularly interested in comments addressing the following:

  1. the current and projected demand for UAS and their parts and components in the United States;
  2. the extent to which domestic production of UAS and their parts and components can meet domestic demand;
  3. the role of foreign supply chains in meeting United States demand for UAS and their parts and components;
  4. the concentration of U.S. imports of UAS and their parts and components from a small number of suppliers or foreign nations and the associated risks;
  5. the impact of foreign government subsidies and predatory trade practices on the competitiveness of the UAS and their parts and components industry, in the United States;
  6. the economic impact of artificially suppressed prices of UAS and their parts and components due to foreign unfair trade practices and state-sponsored overproduction;
  7. the potential for foreign nations and companies to weaponize their control over supplies of UAS and their parts and components;
  8.  the potential for foreign nations and companies to weaponize the capabilities or attributes of foreign-built UAS systems and their parts or components;
  9. the feasibility of increasing domestic capacity for UAS and their parts and components to reduce import reliance;
  10. the impact of current trade policies on domestic production of UAS and their parts and components, and whether additional measures, including tariffs or quotas, are necessary to protect national security

Comments must be submitted via the Federal rulemaking portal at: www.regulations.gov. The Docket ID for this notice is BIS-2025-0059, and submitters must refer to XRIN 0694-XC130 in all comments. In initiating this investigation, the Secretary of Commerce must, within 270 days, submit a report to President Trump with findings and recommendations on potential actions to mitigate any national security threats. While the Section 232 process allows for public hearings, it is unknown at this time whether Secretary of Commerce Howard Lutnick will direct such a process.

On July 1, 2025, the Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act, as amended, to determine the effects on the national security of imports of polysilicon and its derivatives (items considered to be critical solar energy inputs). The Department’s Bureau of Industry and Security (BIS) subsequently issued a Notice of Request for Public Comments indicating that interested parties may submit written comments, data or other information pertinent to the investigation no later than August 6, 2025.

BIS is particularly interested in comments addressing:

  1. the current and projected demand for polysilicon and its derivatives in the United States;
  2. the extent to which domestic production of polysilicon and its derivatives can meet domestic demand;
  3. the role of foreign supply chains in meeting U.S. demand for polysilicon and its derivatives;
  4. the concentration of U.S. imports of polysilicon and its derivatives from a small number of suppliers and the associated risks;
  5. the impact of foreign government subsidies and predatory trade practices on the competitiveness of the polysilicon and its derivatives, in the United States;
  6. the economic impact of artificially suppressed prices of polysilicon and its derivatives due to foreign unfair trade practices and state-sponsored overproduction;
  7. the potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of polysilicon and its derivatives;
  8. the feasibility of increasing domestic capacity for polysilicon and its derivatives to reduce import reliance;
  9. the impact of current trade policies on domestic production of polysilicon and its derivatives, and whether additional measures, including tariffs or quotas, are necessary to protect national security; and
  10. any other relevant factors.

Comments must be submitted via www.regulations.gov. The Docket ID for this notice is BIS-2025-0028, and submitters must refer to XRIN 0694-XC128 in all comments. In initiating this investigation, the Secretary of Commerce must, within 270 days, submit a report to President Donald Trump with findings and recommendations on potential actions to mitigate any national security threats. While the Section 232 process allows for public hearings, it is unknown at this time whether Secretary of Commerce Howard Lutnick will direct such a process.

On July 11, 2025, President Donald Trump issued an Executive Order directing that the February 2020 acquisition of Jupiter Systems, LLC of Delaware, and several of its foreign based subsidiaries (Jupiter), by Suirui International Co., Ltd. (Suirui), a Hong Kong/Chinese company, be unwound. Stating only that there is “credible evidence” Suirui might take action that threatens to impair the national security of the United States, the president has ordered that divestment occur within the next 120 days, unless an extension is granted.

The authority of the president to suspend or prohibit certain foreign investment transactions is pursuant to Section 721 to the Defense Production Act of 1950, as amended, and implementing regulations governing the Committee on Foreign Investment in the United States (CFIUS). The Executive Order requires that Suirui divest “all interests and rights” in Jupiter, Jupiter’s tangible and intangible assets or property, including its intellectual property, non-public source code associated with Jupiter products, and most customer contracts. The assets and operations of two Jupiter subsidiaries located in China and Hong Kong are not required to be divested, so long as such assets and operations were acquired or created after the February 2020 acquisition by Suirui.

Beginning immediately, Suirui must ensure that their personnel “refrain from accessing Jupiter’s non-public source code, non-public technical information, information technology systems, products, parts and components, books and records, or facilities in the United States, unless otherwise approved by CFIUS.” 

In order to effectuate the divestment, Suirui must identify and obtain approval from CFIUS for the intended buyer of Jupiter and its assets. In doing so, it must certify in writing to CFIUS that it has destroyed or transferred all intellectual property or non-public source code associated with Jupiter products in their possession or control. CFIUS has authority to audit the divestment to ensure such destruction or transfer has occurred. CFIUS will implement measures it deems necessary and appropriate to verify and enforce compliance with this Executive Order and any conditions imposed by CFIUS during the period of divestment.

On July 8, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13N, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4. Such transactions are allowable provided they are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Directive 4 prohibits any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.

Previous GL 13N was set to expire on July 9, 2025; the revised GL 13N is set to expire on October 9, 2025.

On July 7, 2025, based on “additional information and recommendation from various senior officials”, President Donald Trump issued an Executive Order determining that it is “necessary and appropriate” to again extend the suspension on reciprocal tariffs originally implemented by an earlier Executive Order on April 2, 2025. The proposed reciprocal tariffs will be suspended until 12:01 a.m. EDT on August 1, 2025.

In his original April 2, 2025 Executive Order, President Trump announced baseline tariffs of 10% for all countries starting April 5, 2025, and, as applicable, additional duty rates increasing up to 50% starting April 9, 2025, on specific countries with which the United States has the largest trade-in-goods deficits or that impose non-tariff barriers on U.S. goods. See Thompson Hine Update of April 3, 2025. Shortly thereafter, however, the president announced he was pausing until July 9, 2025, the country-specific reciprocal tariffs and, instead, leaving in place for 90 days the baseline 10% tariffs (with the exception of certain tariffs on China that remain in place) to allow for negotiations and efforts to achieve agreements with other countries. See Thompson Hine Update of April 10. 2025.

While negotiations with other countries continue, President Trump sent letters to certain trade partner countries — Indonesia, Japan, Malaysia, South Korea, Thailand, and others — informing each of the reciprocal tariff rate that will be applied on August 1, 2025. These reciprocal tariffs appear to range from 25% to 40%, with the possibility of lower rates if acceptable agreements are reached, or of further increases if there is no agreement or the other country raises its tariff rates. In addition, in a social media post, President Trump separately threatened to place an additional 10% tariff on “any country aligning themselves with the anti-American policies of BRICS [Brazil, Russia, India, China, South Africa and six other countries].”

For the first time, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) invoked the Fentanyl Sanctions Act and the Fend OFF Fentanyl Act on June 25, 2025, to issue three separate orders that each designate a Mexico-based financial institution as a “primary money laundering concern in connection with illicit opioid trafficking.” The three banks are CIBanco S.A., Institution de Banca Multiple (“CIBanco”); Intercam Banco S.A., Institución de Banca Multiple (“Intercam”); and Vector Casa de Bolsa, S.A. de C.V. (“Vector”). Effective July 21, the three orders prohibit covered financial institutions from engaging in “transmittals of funds” involving the designated institutions.

The specific conduct giving rise to these designations varies by institution, but FinCEN found that each engaged in a “long-standing pattern of associations, transactions, and provision of financial services that facilitate illicit opioid trafficking by Mexico-based cartels,” including the procurement of precursor chemicals from China for unlawful purposes.

These orders prohibit any “covered financial institution,” as defined in 31 C.F.R. § 1010.100(t), from engaging in “transmittals of funds.” A “covered financial institution” refers to an agent, agency, branch, or office within the United States of any (i) bank (except bank credit card systems), (ii) broker or dealer in securities, (iii) money services business (i.e., a person that accepts checks or money in an amount greater than $1,000 on a given day in return for currency or a combination of currency and other monetary instruments), (iv) telegraph company, (v) authorized casino, (vi) card club or similar gaming establishment, (vii) person subject to supervision by any state or Federal bank supervisory authority, (viii) futures commission merchant, (ix) introducing broker in commodities, or (x) mutual fund. Engaging in “transmittals of funds” means “sending and receiving of funds, including convertible virtual currency.”

As noted in the orders, the sanctions are effective 21 days from their date of publication in the Federal Register to ensure compliance (i.e., until July 21, 2025). Violations may result in civil penalties of up to twice the value of transaction or $1,776,364 per violation, and criminal penalties of up to $1 million per transaction for willful violations.

Although the sanctions only directly impact covered financial institutions, other parties should consider that it may be difficult to process payments to or from accounts at these banks, as payments may not be processed by covered financial institutions. Furthermore, additional due diligence may be advisable for any transactions involving these banks, as they may raise red flags related to money laundering.

On June 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The EO does not provide relief to certain officials and persons of the former regime of Bashar al-Assad, ISIS or other terrorist organizations, human rights abusers, those linked to chemical weapons or proliferation-related activities, or other persons that threaten the peace, security, or stability of the United States, Syria, and its neighbors. 

The below offers an overview and summary of the numerous actions taken under the EO. Note, however, certain sanctions and controls prohibiting exports of U.S.-origin products remain in place as they were mandatorily implemented under legal statutes. The Secretary of State will be required to submit to the appropriate Congressional committees reports and certifications required by two Acts (noted below) prior to the actual implementation of any relaxation of covered sanctions or export controls.

As such, a close review of the June 30, 2025 EO is necessary to ensure whether a U.S. company or person can now fully engage in activities in Syria and/or with Syrian entities or persons.

Revoking OFAC Syria Sanctions but Maintaining Designations on Bashar al-Assad and His Associates

Effective July 1, 2025, the EO terminates the national emergency declared by the United States regarding Syria and revokes six past EOs that implemented sanctions and blocked property of various persons in Syria and senior officials in the Government of Syria. 

In revoking the numerous EOs the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has concurrently removed 518 individuals and entities from the Specially Designated Nationals (SDN) List sanctioned under the Syria sanctions program, thus “lifting sanctions on such individuals and entities critical to Syria’s development, the operation of its government, and the rebuilding of the country’s social fabric.” The list of persons and entities removed from the SDN List can be found here.

As a result of President Trump’s June 30 EO, OFAC will also remove the Syrian Sanctions Regulations, 31 C.F.R. part 542 from the Code of Federal Regulations following the July 1, 2025 revocation.

However, the scope of sanctions on certain persons impacted by EO 13894 (October 14, 2019, providing for menu-based sanctions including travel restrictions to the United States and isolation from the United States’ financial system for foreign persons who engage in or finance the obstruction, prevention, or disruption of a ceasefire or political solution to the conflict in Syria) and EO 14142 (January 15, 2025) have been amended in order to continue “to ensure meaningful accountability for perpetrators of war crimes, human rights violations and abuses, and the proliferation of narcotics trafficking networks in and in relation to Syria during the former regime of Bashar al-Assad and by those associated with it.” 

As such, OFAC designated 139 individuals and entities pursuant to EO 13894 and placed them on the SDN List. These individuals and entities include former government officials of the former regime of Bashar al-Assad (including family members), his associates, human rights abusers, drug traffickers, persons linked to chemical weapons activities, ISIS or its affiliates, Iranian proxies, and others who may engage in the disruption or prevention of efforts to promote a stable Syria. The list of persons and entities added to the SDN List can be found here.

OFAC has also released Frequently Asked Questions 1220-1223 to provide guidance on continued reliance on OFAC Syria General License 25 and addressing other aspects of President Trump’s EO of June 30, 2025.

Suspension of Certain Statutory Sanctions under the Caesar Syria Civilian Protection Act

The EO directs the Secretary of State to examine whether certain criteria set forth in the Caesar Act have been met and evaluate suspending sanctions. This law, enacted in 2019, established mandatory sanctions to target foreign persons who facilitated the Assad regime’s acquisition of goods, services, or technologies that supported the regime’s military activities as well as its aviation and oil and gas production industries. If such criteria have been met, the Secretary of State may suspend the imposition of such sanctions, so long as continued review of the situation in Syria is undertaken to ensure that reimposition of any sanctions are not necessary.

Note that the Treasury and State Departments in May 2025 waived sanctions under the Caesar Act. See Thompson Hine Update of May 27, 2025. With the June 30, 2025 EO, the State Department has now formally terminated economic sanctions against various Syrian entities and, as previously noted, OFAC has removed such persons and entities from its SDN List. Thus, all property and interests in property of such designated persons that are in the United States or in possession or control of U.S. persons are unblocked. Additionally, all entities owned, either directly or indirectly, 50% or more by one or more blocked persons are also unblocked. 

In a brief statement, Secretary of State Marco Rubio stated that he would now “examine the potential full suspension of the Caesar Act.”

Waiver of Export Controls under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003

The EO also waives and relaxes the application of certain export controls on items on the Commerce Control List and certain provisions of the Syria Accountability Act. President Trump has determined that it is in the national security interests of the United States to waive such restrictions and has directed the Secretary of State to submit to the appropriate Congressional committees the report and certification required by this Act. 

This Act requires the President to implement two or more sanctions from a menu-based list and includes prohibiting the export of U.S. origin products (other than food and medicine) to Syria. It should be noted, however, that while the President has made the required determination that Syria meets the requirements for sanctions relief under the Syria Accountability Act, as of June 30, 2025, such a determination has not been certified to Congress. Thus, the lifting of the prohibition of exports to Syria of items on the Commerce Control List of dual-use items in the Export Administration Regulations (EAR), identifying which export controls will be relaxed, and establishing any continuing requirements to obtain necessary licenses from the Department of Commerce’s Bureau of Industry and Security (BIS) have not been implemented and these sanctions have not been immediately lifted.

Waiver of Sanctions under the Chemical Biological Weapons Control and Warfare Elimination (CBW) Act

The EO also waives various sanctions imposed on Syrian under the CBW Act due to the prior use of chemical weapons under the former regime of Bashar al-Assad. This includes the lifting of restrictions on foreign assistance; restrictions on U.S. government credit, credit guarantees, or other financial assistance; restrictions on the export of certain national security-sensitive goods and technology; and restrictions on U.S. banks from making loans or providing credit to the Government of Syria. Again, while the President has made the determination that Syria meets the requirements for sanctions relief under this Act, such a determination and a report must be transmitted to Congress. The EO states that these waivers to allow the resumption of financial aid will be effective 20 days after appropriate notice has been made to the Congress.

Other Actions

The EO also directs the Secretary of State to undertake all appropriate action with respect to the designation of certain Syrian persons and entities, including Hay’at Tahrir al-Sham’s (HTS), as “Specially Designated Global Terrorists” and to review the designation of Syria as a State Sponsor of Terrorism. The Secretary of State is also directed to take appropriate steps to advance U.S. policy objectives at the United Nations to support a Syria that is stable and at peace and to explore avenues at the United Nations to provide sanctions relief.

In a related Fact Sheet issued by the White House, it is noted that President Trump “is committed to supporting a Syria that is stable, unified, and at peace with itself and its neighbors.” However, the United States will seek to “reengage constructively,” thus the Trump Administration will continue “to guard against all threats and monitor progress on key priorities.”

Thompson Hine will continue to monitor the relaxation of sanctions and exports controls on Syria and report further developments as necessary.

On June 30, 2025, President Donald Trump reissued National Security Presidential Memorandum (NSPM-5) to address U.S. policy towards Cuba. This version of NSPM-5 revises and amends the earlier version of NSPM-5 issued in June 2017 (see Thompson Hine Update of June 20, 2017).

NSPM-5 includes several policy statements including continued support of economic embargo of Cuba as set forth in the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, including by opposing measures that call for an end to the embargo at the United Nations and other international forums. The administration is also directed to ensure adherence to the statutory ban on tourism to Cuba (relaxed during the Obama administration) and to not reinstate the “Wet Foot, Dry Foot” policy which encouraged “unlawful” travel by Cuban nationals to the United States.

The memorandum notes that policy interests include: advancing Cuban human rights; encouraging the growth of a Cuban private sector independent of government control; enforcing final orders of removal against Cuban nationals in the United States; protecting the national security and public health and safety of the United States, including through proper engagement on criminal cases and working to ensure the return of fugitives from American justice living in Cuba or being harbored by the Cuban government; supporting United States agriculture and protecting plant and animal health; advancing the understanding of the United States regarding scientific and environmental challenges; and facilitating safe civil aviation.

Accordingly, by July 30, 2025, the Secretary of the Treasury and the Secretary of Commerce, as appropriate and in coordination with the Secretary of State and the Secretary of Transportation, are directed to initiate a process to adjust current regulations regarding transactions with Cuba. Such efforts will include, but are not limited to:

  • The Secretary of State identifying any entities that are under the control of, or act for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel, and publish a list of those identified entities and prohibit direct or indirect financial transactions with such entities.
  • The Secretary of the Treasury initiating a process to adjust current regulations to ensure adherence to the statutory ban on tourism to Cuba, and regularly auditing travel to Cuba to ensure that travelers are complying with relevant statutes and regulations.
  • The Department of the Treasury expanding its current regulation defining the term “prohibited officials of the Government of Cuba” to include additional Cuban government ministers, state agencies, and certain employees of the Ministry of the Interior, Ministry of Defense, and Cuban state-run media organizations.
  • The Secretary of State convening a task force to examine the technological challenges and opportunities for expanding internet access in Cuba, including through federal government support of programs and activities that encourage freedom of expression through independent media and internet freedom in Cuba.
  • The Secretary of State and the Secretary of Homeland Security continuing to discourage unlawful migration from Cuba and carrying out duties regarding interdiction of migrants.

Accordingly, parties engaged in transactions involving Cuba should closely monitor developments and any forthcoming regulatory changes.