Cuba Action Team

Holland & Knight's Cuba Action Team is at the forefront of helping clients capitalize on the changes and expanded market opportunities involving Cuba. With more than 30 years of experience representing U.S. and international clients who are conducting inbound and outbound business in Latin America and the Caribbean, and more than 20 years counseling clients on Cuba-related issues, our lawyers are distinctly positioned to address client needs and goals with our full-service representation and value-added services around the globe.

Our team is comprised of a deep bench of attorneys – primarily from Holland & Knight's Latin America, International Trade and Financial Services practices – with extensive experience assisting U.S. and non-U.S. clients on Cuban trade embargo issues across a wide range of industries, including financial services, airlines, shipping lines, exporters, insurers, agricultural and pharmaceutical companies and organizations. We also have a significant cross-border presence from our offices in Miami, New York, Mexico City, Bogotá and beyond. With a multilingual and multicultural understanding, our attorneys frequently counsel clients on Cuban matters and do so with the utmost sensitivity to both politics and the relationship between the United States, Cuba and other key countries.

Although the U.S. embargo and the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 (also known as the Helms-Burton Act) are continuing to affect business relations, the change in policy toward Cuba announced by former President Barack Obama on Dec. 17, 2014, and the amendments to the Cuban Asset Control Regulations (CACR) subsequently ensued by the OFAC on Jan. 16 through Oct. 14, 2016, significantly relaxed the sanctions against Cuba. The amendments incremented commerce and flow of information to and from Cuba and lifted certain decades-long travel restrictions. Following this brief opening period, on Nov. 9, 2017, the CACR were further amended to impose additional requirements on the travel authorizations and to restrict direct financial transactions with entities under the structure of the Cuban military, among other less significant changes; however, most of the amendments relaxing the sanctions through 2016 remain in place.

The most recent amendments to the CACR, which became effective on May 29, 2024, include general licenses that promote the exchange of communication with the Cuban people over the internet; support access to U.S. internet services, applications and e-commerce platforms; and support independent Cuban private sector entrepreneurs, among other measures, by expanding access to certain U.S. financial services. 

Deep Experience and Dedication to Our Clients

Holland & Knight's Cuba Action Team is continually responding to client inquiries relating to the impact of these changes, and provides advice that encompasses both the U.S. perspective as well as the Cuban perspective, as it pertains to the potential business opportunity or transaction. In addition to our thorough knowledge of U.S.-Cuba policy laws, our team remains updated on the latest regulatory and economic developments that may affect imports and exports, U.S.-Cuba travel and communication, and bank transactions between the two nations, as well as clients' business interests within the region.

Furthermore, our attorneys have an in-depth understanding of the business opportunities and legal framework to conduct business in the region due to our background and leadership positions in such organizations as the Cuban American Bar Association, Cuban-American Caucus of State Legislators, Cuban American National Foundation and Florida Governor's Cuba Commission, as well as the Florida International Bankers Association's (FIBA) Sanctions Subcommittee. Especially in the areas of foreign investment, financing, regulatory compliance, complex and nuanced defense strategies, and cross-border structuring, our experience with OFAC, the U.S. Departments of State, Commerce and Agriculture, and esteemed banking associations and institutions makes our firm a vital partner in clients' strategic planning on how to tap into the next wave of opportunities in the region.

Holland & Knight regularly counsels local and international clients in cross-border transactions, international trade and taxation, mergers and acquisitions, joint ventures, capital markets, venture capital and private equity investments, project finance, real estate, international licensing and franchising, transportation and infrastructure, international litigation and arbitration, labor and employment, regulatory advice and government matters. Our U.S. and international offices – combined with the depth and scale of our practices, regional relationships and global reach, including a well-established working experience with foreign counsel around the world – enables Holland & Knight to provide comprehensive and seamless legal services to our clients, regardless of location.

Because changing policy creates new opportunities, our Cuba Action Team is dedicated to helping clients develop successful strategies through careful analysis. Having been ranked among Cuba Corporate/Commercial: International Firms in the Chambers Latin America guide each year since 2018, including in 2024, the lawyers on our team have been praised for providing "prompt and thorough counsel regardless of the nature or magnitude of the issue," with clients reporting, "we have complete trust in their services and capabilities."

Clients in the U.S., Latin America, Europe and other key areas look to our firm for the latest advice on business development and public policy. Holland & Knight's substantial experience in a wide range of business sectors is enhanced by our established working relationships with key regional business and government leaders. From intelligence on expansion opportunities for U.S. companies into Cuba to sponsoring symposiums on business ventures, legal trends and challenges, clients look to Holland & Knight for our collaboration across practices, offices and jurisdictions, our highly focused management of matters and cases, and our seamless and efficient support.