Welcome to our web site, and thank you for taking the time to learn more about this practice and how we can potentially assist you.  We represent both individuals and corporate clients in the areas of Immigration, International Trade, and Compliance.

Immigration Services:

For information on our Immigration Services click here.

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Trade and Commerce Services:

U.S. persons need a License to export and import all items subject to the Export Administration Regulations (EAR) between U.S. and Cuba with a few exceptions (License Exceptions). The Firm will file and obtain the required licenses for you before engaging in transactions with Cuban nationals.

The Firm assists licensed or exempt U.S. persons to establish Physical Presence in Cuba, including the following:

(1) Leasing physical premises, including office, warehouse, classroom, or retail outlet space, and securing related goods and services, including for use in and to pay fees related to the operation of the physical premises;

(2) Marketing related to the physical presence;

(3) Employment of Cuban nationals in Cuba;

(4) Employment of individuals who are persons subject to U.S. jurisdiction; and

(5) Opening and maintaining bank accounts at Cuban financial institutions to engage in authorized transactions.

Treasury Services:

U.S. persons need a License to do business in Cuba or with a Cuban national. U.S. federal regulations prohibit all persons subject to the jurisdiction of the U.S. from dealing in property in which Cuba or a Cuban national has an interest unless such transactions are authorized pursuant to a general or specific license issued by OFAC or are otherwise exempt. The Firm will guide you throughout the licensing process and will document all the evidence required to file and obtain the License.

The Cuban Assets Control Regulations (Regulations) administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) permit the following legal and counseling services on the requirements of and compliance with the laws of the U.S. or any jurisdiction within the U.S., provided that such advice and counseling are not provided to facilitate transactions in violation of the Regulations:

1)    Representation before the U.S. Department of Treasury and U.S. Department of Commerce regarding the issuance of licenses under the Regulations;

2) Representation of U.S. and foreign nationals regarding proposed business activities in Cuba, including researching U.S. claim holders, potential adverse consequences under the Regulations and advising on U.S. policy issues;

3) Representation in negotiations with Cuban entities for licensed transactions with U.S. entities, including meetings with Cuban business and government officials and drafting of agreements; and

4) Representation of clients before U.S. administrative agencies regarding violations of the Regulations.

Regulatory Compliance Services:

Regulators have dramatically stepped up enforcement of anti-bribery and corruption regulations and this trend is expected to continue. U.S. persons doing business with Cuban State Enterprises and Cuban Government Officials must protect themselves by ensuring their anti-bribery and corruption compliance programs are comprehensive and effective. The Firm assists you in implementing an effective corporate compliance policy to mitigate such risks.

The Firm provides solutions that help clients to comply with the Foreign Corrupt Practice Act (FCPA) and the United Nations Convention against Corruption that have been ratified by 167 states, including the U.S. and Cuba.

The Firm focuses the required due diligence regarding compliance with both the FCPA and the Convention in two aspects:

 Initial due diligence – this step is necessary in evaluating what risk is involved in doing business with an entity prior to establishing a relationship and assesses risk at that point in time.

Enhanced due diligence – this is the process of periodically evaluating each relationship in Cuba. This process will be performed indefinitely as long as a relationship exists, and usually involves comparing the companies and executives to a database of Cuban officials and state own enterprises.