Since 1962 when President John F. Kennedy proclaimed an embargo on trade between the United States and Cuba, restrictions against U.S. persons, as defined by 31 C.F.R. Section 515.329, have been in effect, with the U.S. Department of the Treasury's Office of Foreign Assets Control, through the Cuban Assets Control Regulations 31 C.F.R. Section 515.101 et seq., and the Bureau of Industry and Security, through the Export Administration Regulations 15 C.F.R. Section 730.1 et seq., primarily implementing such prohibitions.

On Dec. 17, 2014, former President Barack Obama announced his intentions to “chart a new course with Cuba.” Obama subsequently issued a series of executive orders resulting in multiple amendments to the CACR, which eased travel restrictions to Cuba and promulgated 12 categories of general licenses for doing business in Cuba.

The 12 categories of general licenses signified great promise in normalizing relations with the island since under the embargo U.S. persons can do business with Cuba only if they qualify for one of the general licenses contained in the CACR or if OFAC grants a specific license for the particular proposed activity.