As we have discussed in prior posts, the Trump Administration has threatened since January 2019 to permit claims under Title III of the Helms-Burton Act for “trafficking” in property claimed by Americans and expropriated by Cuba to proceed. Title III has been suspended since the Helms-Burton Act was enacted in 1996.
On April 17, 2019, the Trump Administration announced that it will no longer maintain the suspension of Title III. This means that as of May 2, 2019, it will be possible for former owners of properties expropriated by the Cuban government to bring claims before the U.S. courts against foreign companies alleged to have “trafficked” with those properties.

We have updated our memorandum on the potential impact of these changes in U.S. law, including measures that foreign companies involved in business related to Cuba may wish to consider.