The Biden-Harris Administration (2021- ) has directed the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury in Washington DC to issue the first license authorizing an entity subject to United States jurisdiction (which is not affiliated directly or indirectly with an individual of Cuban descent) to deliver a direct equity investment to and authorizing direct financing for an officially registered privately-owned company (in the service sector) located in the Republic of Cuba and owned by a Republic of Cuba national. Neither entity in the transaction is connected with the other in terms of commercial relationships or family relationships. The parties did not have connectivity prior to this transaction.

The license application was submitted to the OFAC on 10 June 2021 by Mr. Robert L. Muse, Esq., a Washington DC-based attorney (Telephone: 202-460-3168; Email: robertmuse@robertmuse.com), and the license was issued by the OFAC in the late afternoon of 10 May 2022. The U.S.-Cuba Trade and Economic Council assisted the parties during the process.

The eleven-month OFAC licensing process resembles the “anticipation” when pouring from a Heinz ketchup container. Eleven months to the day from when the license application was submitted to the OFAC, the ketchup poured from the container….

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