In June, the Trump administration announced its new Cuba policy, which was presented as a cancellation of the Obama administration’s agreement to normalize U.S. relations with “the island.” This new policy tightens restrictions on U.S. persons who wish to travel to Cuba and limits the ability of U.S. businesses to engage in commerce with GAESA (Grupo de Administración Empresarial S.A.), the Cuban military’s business and commerce division.

One specific consequence of Trump’s new policy will be the prohibition of U.S. companies to establish new relationships with certain tourism-related enterprises, including hotels, many of which are run by GAESA’s subsidiary, Gaviota. It will also limit foreign investment in Cuba’s Special Economic Development Zone of Mariel (Zona de Desarrollo Integral de Mariel), since it is controlled by another GAESA subsidiary. Notwithstanding the new policy, which becomes effective following the adoption of regulations by the Treasury Department, Cuba remains open for business. Specifically, U.S. businesses can pursue ventures in industries that are not controlled by the Cuban military and intelligence services, including telecommunications, airports, cruise ports and agriculture.