On May 20, fulfilling a campaign promise to a room full of supporters in Miami, President Donald Trump announced, “I am canceling the last administration's completely one-sided deal with Cuba.” While this declaration played well to his supporters, it was far from true. Most of the policy openings introduced by President Barack Obama remain in place. We still have an embassy in Havana, commercial flights and cruises to the island continue and certain American industries continue shipping products to the island country. So what changed? Basically, there were two major changes to the existing policy.

Travel by Americans for pure tourism without an allowed exemption is no longer allowed. The exemptions were still in place under the Obama policy but they were not being strictly policed. As long as it was likely to lead to exchanges with the Cuban people, Americans were free to book a trip to Cuba without any formalities. The 12 categories of authorized exemptions include family visits, journalists, cultural exchanges, educational trips, humanitarian trips and the ambiguous “support for the Cuban people.” This will likely result in a resurgence of the role of the licensed tour company to help Americans comfortably comply with the regulations.

The second major change involves who an American can spend money with on the island. The Secretary of State has been empowered to compile a list of forbidden Cuban entities that are “under the control of, or act for or on behalf of, the Cuban military, intelligence or security services or personnel … its affiliates, subsidiaries and successors.” This policy specifically names and targets a mega company owned and operated by the Cuban military, Grupo de Administracion Empresarial S.A. (GAESA), its affiliates, subsidiaries and successors. This is likely to have a deep impact on doing business with Cuba since Gaesa owns numerous subsidiaries throughout the island particularly in the lucrative tourist industry. It is also likely to create some initial confusion since affiliates seems to expand the reach of the prohibition beyond government-owned entities and successors could in theory capture private entities who take over previous manufacturing or services offered by a government company.