CUBA: To Whom Can I Sell Without A License?

As discussed in my prior post entitled “What Can I Sell Into Cuba Without A License?”, you can only sell certain categories of items and only to Cuban persons or entities who are engaged in “private sector” economic activities.

“Private sector” activities are those “generated by private individuals and groups as enterprises for profit”, plus those “generated by non-profit organizations and charities.” Companies that are government owned, operated or controlled do not qualify; but because much Cuban importing activity is controlled by the government, US exporters can sell to private-sector entities through such government-controlled importers, subject to certain conditions.

Caution:  All sales to Cuba are subject to a number of conditions and restrictions.  You should not engage in them without consulting counsel.

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