If a United States-based company or United States-based subsidiary of a non-United States-based company has 1) a license application pending before the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury or Bureau of Industry and Security (BIS) of the United States Department of Commerce or 2) has considered, but not applied for a license from the OFAC or BIS, they are advised to move swiftly to secure a license.

A license issued by the OFAC or BIS is generally valid for one-year or more; so having an executable license prior to 20 January 2017 will be of value as the Trump Administration might not invalidate a license previously issued.

Having a license be active (exports, imports, provision of services, etc.) prior to 20 January 2017 would provide greater insurance against the invalidation of a license that exists, but has not had components implemented.

Economic Eye On Cuba

Companies Seeking Licenses From The OFAC Or BIS Have 60 days.... Or Face Uncertainty

U.S. - Cuba Trade and Economic Council, Inc.