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Omnibus Appropriations Act May Increase US Exports to Cuba

International Law Office
January 22, 2010

The recently signed Omnibus Appropriations Act may increase sales to Cuba of agricultural commodities, medicine and medical products by reversing a 2005 interpretation of “cash in advance” as used in the Trade Sanctions Reform Act of 2000. On December 16, 2009, the President signed into law H.R. 3288, which provides fiscal year 2010 appropriations for several departments in the U.S. government. Section 619 of this act reverses a 2005 rule by the Treasury Department’s Office of Foreign Assets Control defining “cash in advance” to require that U.S. suppliers receive payment before goods are loaded onto a carrier for export to Cuba, thereby making trade with Cuba more difficult.

This Sidley Update was republished by ILO in its Trade & Customs Newsletter.

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