Tropicola (the Republic of Cuba's version of Coca-Cola) and rum brands, Ron Caney and Ron Varadero, are listed in the United States Department of State List of Entities and Subentities Associated with Cuba [LINK].
The summary references that "direct financial transactions will be generally prohibited" with such entities and subentities as they are affiliated with the Revolutionary Armed Forces (FAR) of the Republic of Cuba and "intelligence, or security services or personnel."
If an individual subject to United States jurisdiction purchases Tropicola, Ron Caney or Ron Varadero from an individual, privately-owned kiosk, cafe, or restaurant (paladar), would that transaction be permitted because it is not "direct" or would it be prohibited because its "fruit of the poisonous tree."
Is the focus meant to be solely upon "commercial engagement" by United States companies relating to the export/import of the products?
Does this mean an individual subject to United States jurisdiction may not purchase and consume Tropicola, Ron Caney and Ron Varadero regardless of the location of the individual? The honor system on steriods.....
Will the regulations serve as a means to promote other Republic of Cuba government-owned beverage brands? Or....
Could this be a (not-so) subtle means by the Trump Administration to promote exports to the Republic of Cuba by Atlanta, Georgia-based The Coca-Cola Company (2016 revenues exceeded US$41.8 billion) and Purchase, New York-based PepsiCo, Inc. (2016 revenues exceeded US$62.8 billion)?
Awaiting a response from the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury and from the United States Department of State.....
U.S. - Cuba Trade and Economic Council, Inc.
Established in 1994, the U.S.-Cuba Trade and Economic Council provides an efficient and sustainable educational structure in which the United States business community may access accurate, consistent, and timely information and analysis on matters and issues of interest regarding United States-Republic of Cuba commercial, economic, and political relations.