Munich, Germany-based Kempinski Hotels S.A. (seventy-five properties in thirty countries) has their second property (the first was Gran Hotel Manzana Kempinski La Habana) in the Republic of Cuba included on the Cuba Restricted List: https://www.kempinski.com/en/cayo-guillermo/cayo-guillermo-resort/
From The United States Department Of State:
The Department of State is publishing an update to its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR). This Cuba Restricted List is also considered during review of license applications submitted to the Department of Commerce's Bureau of Industry and Security (BIS) pursuant to the Export Administration Regulations (EAR).
DATES: The Cuba Restricted List is updated as of July 26, 2019.
LINK To PDF Of List
On June 16, 2017, the President signed National Security Presidential Memorandum-5 on Strengthening the Policy of the United States Toward Cuba (NSPM-5). As directed by NSPM-5, on November 9, 2017, the Department of the Treasury's Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register amending the CACR, 31 CFR part 515, and the Department of Commerce's Bureau of Industry and Security (BIS) published a final rule in the Federal Register amending, among other sections, the section of the Export Administration Regulations (EAR) regarding Cuba, 15 CFR 746.2. The regulatory amendment to the CACR added § 515.209, which generally prohibits direct financial transactions with certain entities and subentities identified on the State Department's Cuba Restricted List. The regulatory amendment to 15 CFR 746.2, notes BIS will generally deny applications to export or re-export items for use by entities or subentities identified on the Cuba Restricted List. The State Department is now updating the Cuba Restricted list, as published below and available on the State Department's website (https://www.state.gov/cuba-sanctions/cuba-restricted-list/).
This update includes four additional subentities. This is the fourth update to the Cuba Restricted List since it was published November 9, 2017 (82 FR 52089). Previous updates were published November 15, 2018 (see 83 FR 57523), March 9, 2019 (see 84 FR 8939), and April 24, 2019 (see 84 FR 17228). The State Department will continue to update the Cuba Restricted List periodically.
The publication of the updated Cuba Restricted List further implements the directive in paragraph 3(a)(i) of NSPM-5 for the Secretary of State to identify the entities or subentities, as appropriate, that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel, and publish a list of those identified entities and subentities with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba.
This document and additional information concerning the Cuba Restricted List are available from the Department of State's website (https://www.state.gov/cuba-sanctions/cuba-restricted-list/).
List of Restricted Entities and Subentities Associated With Cuba as of July 26, 2019
Below is the U.S. Department of State's list of entities and subentities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. For information regarding the prohibition on direct financial transactions with these entities, please see 31 CFR 515.209. All entities and subentities were listed effective November 9, 2017, unless otherwise indicated.
* * * Entities or subentities owned or controlled by another entity or subentity on this list are not treated as restricted unless also specified by name on the list. * * *
State Department Updates the Cuba Restricted List
07/26/2019 10:32 AM EDT
The State Department has updated the Cuba Restricted List to add four sub-entities owned by the Cuban military. The changes take effect today, July 26, as Cuba celebrates more than 60 years since the start of the Cuban Revolution. Sixty years after Castro promised to improve the lives of the Cuban people, the revolution continues to fail its people by squandering Cuba’s economic potential through mismanagement and oppressing brave Cubans that continue the fight for freedom. The Department remains committed to ensuring U.S. funds do not directly support Cuba’s state security apparatus, which not only violates the human rights of the Cuban people, but also exports this repression to Venezuela to support the corrupt Maduro regime.
In accordance with the June 2017 National Security Presidential Memorandum-5, “Strengthening the Policy of the United States Toward Cuba,” the U.S. government generally prohibits direct financial transactions with listed entities and sub-entities because they would disproportionately benefit the Cuban military, intelligence, and security services or personnel at the expense of the Cuban people or private enterprise in Cuba.
For more information on the regulations prohibiting direct financial transactions with entities and sub-entities on the Cuba Restricted List, please refer to the November 2017 regulatory amendments by the Departments of the Treasury (31 CFR part 515) and Commerce (15 CFR parts 730-774).