Saturday, April 25, 2015

Let 201 flowers bloom (but no more!): Cuba's list of permitted self-employment occupations

As an appendix to our recent book, Entrepreneurial Cuba: The Changing Policy Landscape (discount order form here), Arch Ritter and I produced the updated, annotated, and translated list of Cuba's 201 permitted self-employment occupations (trabajos por cuenta propia) provided below.

We have even taken the liberty of highlighting the (few) occupations (goods and services) on the list that might be marketable in the U.S.

Given that there's been so much talk recently of potential U.S. economic engagement with Cuba - and its private "non-state" sector - (& especially in the wake of Gov. Andrew Cuomo's delegation to Cuba last week) I wanted to share this list with readers of El Yuma as a necessary reality check.

In other words, as the Obama administration begins the laudable and necessary task of hollowing out the U.S. embargo (until Congress finally votes to just get rid of the damn thing!), we should remember that:

The Cuban government has an auto-bloqueo (internal embargo) of its own that continues to act as a major obstacle to small- and medium-size business development on the island.

Note: While our sources are at the end of the list, a special H/T goes out to the Associated Press, which published a preliminary translation of the then 178-occupation list on January 30, 2011 (likely done by the then Havana bureau chief Paul Haven, who also published this article at the same time), and to Richard Feinberg, whose own report, "Soft Landing in Cuba? Emerging Entrepreneurs and Middle Classes," includes a very helpful and detailed translation of the by then slightly expanded list of 201 occupations (see pp. 54-57).

CLICK HERE TO ACCESS THE DOCUMENT AS A PDF

Sunday, April 19, 2015

GOVERNOR CUOMO ANNOUNCES INDUSTRY LEADERS PARTICIPATING IN UPCOMING TRADE MISSION TO CUBA


For Immediate Release: 4/19/2015
GOVERNOR ANDREW M. CUOMO
State of New York | Executive Chamber
Andrew M. Cuomo | Governor


GOVERNOR CUOMO ANNOUNCES INDUSTRY LEADERS PARTICIPATING IN UPCOMING TRADE MISSION TO CUBA

Governor Andrew M. Cuomo today announced that leaders from business and higher education will be joining New York's trade mission to Cuba – the first Governor-led state trade mission to Cuba since President Obama began the process to normalize diplomatic relations between the United States and Cuba. The trade mission delegation will depart on April 20, 2015.

"The representatives in New York's delegation will help ensure Empire State companies are at the front of the line as the door opens to a market that has been closed to U.S. enterprise for over half a century." Governor Cuomo said. "These industry leaders will serve as ambassadors for all that New York State has to offer and will help form the foundation for a strong economic relationship between New York and Cuba as legal restrictions on trade are eased in the future."

In addition to the below industry leaders, the delegation is joined by Assembly Speaker Carl Heastie, Senate Minority Leader Andrea Stewart-Cousins and Senate Independent Democratic Conference Leader and Coalition Co-Leader Jeffrey Klein.

Howard Zemsky, President, CEO & Commissioner of Empire State Development, said, "New York State will lead a series of economic development trade missions that will strengthen existing trade relationships and create new ones. These trade missions will increase visibility for New York State and help New York businesses expand their global footprint."

The Governor's trade mission includes representatives from a variety of industries, including air travel, health care, biotechnology, pharmaceuticals, financial services, agriculture and higher education. Specifically joining the Governor's trade mission is:

Air Travel – JetBlue and the Plattsburgh International Airport

Headquartered in Long Island City with more than 6,000 New York-based jobs, JetBlue is New York's Hometown Airline™, and a leading carrier in Boston, Fort Lauderdale-Hollywood, Los Angeles (Long Beach), Orlando, and San Juan. JetBlue carries more than 32 million customers a year to 87 cities in the U.S., Caribbean, and Latin America with an average of 875 daily flights. JetBlue will be represented on the trade mission by Robin Hayes, CEO; and James G. Hnat, EVP General Counsel & Governmental Affairs.

The Plattsburgh International Airport is an important regional transportation hub in Upstate New York. The airport is represented by Garry Douglas, President and CEO of the Plattsburgh-North Country Chamber of Commerce. Mr. Douglas also serves as co-chair of the North Country Regional Economic Development Council.

Financial Services – MasterCard

MasterCard is a technology company in the global payments industry that operates the world's fastest payments processing network, connecting consumers, financial institutions, merchants, governments and businesses in more than 210 countries and territories. MasterCard's New York headquarters are in Purchase, and the company has approximately 1,500 New York-based employees. They will be represented by Walt M. Macnee, Vice Chair, MasterCard.

Health/Biotech/Pharma NY Genome Center, Pfizer, Regeneron and the Roswell Park Cancer Institute

The NY Genome Center is an independent, nonprofit at the forefront of transforming biomedical research and clinical care with the mission of saving lives. As a consortium of renowned academic, medical and industry leaders across the globe, NYGC focuses on translating genomic research into clinical solutions for serious disease. The Center will be represented on the trade mission by Dr. Robert Darnell, CEO; and Carol Ashe, Chief Business Officer.

Pfizer, one of the world's premier innovative biopharmaceutical companies, employs more than 4,600 people in New York State. Pfizer's global headquarters are based in Manhattan, and the company also has a vaccines and biologics research site in Rockland County, NY. Pfizer will be represented on the trade mission by its Chief Medical Officer and Executive Vice President Freda Lewis-Hall, M.D.

Regeneron is a leading science-based biopharmaceutical company based in Tarrytown, with approximately 2,500 employees that discovers, invents, develops, manufactures, and commercializes medicines for the treatment of serious medical conditions. Regeneron will be represented on the trade mission by CEO Dr. Leonard Schleifer.

The mission of Roswell Park Cancer Institute is to understand, prevent and cure cancer. Founded in 1898, RPCI is one of the first cancer centers in the country to be named a National Cancer Institute-designated comprehensive cancer center and remains the only facility with this designation in Upstate New York. The Institute will be represented on the trade mission by CEO Dr. Candace Johnson, as well as Department of Immunology Chair Dr. Kelvin Lee.

Technology – Infor

Infor specializes in enterprise software applications for a variety of industries, including health care, with headquarters in Manhattan and approximately 12,700 total employees. Infor will be represented on the trade mission by Charles Phillips, CEO; and Steve Fanning, VP Healthcare Industry Strategy.

Agriculture – Cayuga Milk Ingredients and Chobani

Cayuga Milk Ingredients began in 2012 as a farmer-owned dairy company located in the Finger Lakes region. Formed from the vision of a small group of farmers, CMI offers locally produced, high-quality, and specialized dairy ingredients. The company's family-owned farms include several multi-generational farmers, some of whose farms date back over 150 years. The company is headquartered in Auburn and will be represented by CEO Kevin Ellis.

Chobani was founded in upstate New York in 2005 by Hamdi Ulukaya, who launched Chobani Greek Yogurt in 2007. Less than six years later, it has become the No.1-selling Greek Yogurt brand in the U.S. with more than a billion dollars in annual sales – making Chobani one of the fastest-growing companies in history. The company is headquartered in Norwich and has approximately 6,000 in-state employees. CEO Mr. Ulukaya will be representing Chobani on the trade mission.

Higher Education – The State University of New York system (SUNY), the largest comprehensive university system in the United States, has helped transform New York State into a world leader in higher education. SUNY educates more than 450,000 students in more than 7,500 academic programs at 64 campuses across New York State. SUNY Chancellor Dr. Nancy L. Zimpher and Dr. Jose F. Buscaglia-Salgado, Director of Caribbean, Latin American, and Latino Studies for the University at Buffalo, will be representing SUNY.

This trade mission is part of Global NY, an initiative launched by Governor Cuomo in 2014. The Global NY trade mission to Cuba will be the first of several trade mission destinations, including Canada, China, Israel and Mexico. With offices in New York, Canada, China, Israel, Mexico, South Africa, and the United Kingdom, Global NY has on-the-ground experts around the world creating new business opportunities for New York State. In addition, the Governor recently unveiled www.global.ny.gov, a one-stop shop for trade and investment and a $35 million Global NY Development Fund which will soon provide loans and grants to help small- and medium-sized New York businesses export abroad.

###



Additional news available at www.governor.ny.gov
New York State | Executive Chamber |
press.office@exec.ny.gov | 518.474.8418

Sunday, April 12, 2015

Tomorrow in Times Square: Tatlin's Whisper #6

Tomorrow in Times Square: Cuban post-performance of TANIA BRUGUERA with 1 minute of freedom.

"Tatlin's Whisper #6"

WHEN:
Monday April 13, 2015 (TOMRROW), from 12M to 2pm

WHERE:
Duffy Square, besides the red stairs and the TKTS stand (north triangle of Times Square, between 45th and 47th streets, and between Broadway y 7th Avenue).

WHO & HOW:
https://www.facebook.com/events/1453674324923395/

By restaging Tania Bruguera's participatory artwork "Tatlin's Whisper #6," we stand in solidarity with her, Angel Santiesteban, Danilo Maldonado "El Sexto," and all other artists around the world who face criminal charges and violence for exercising their basic human right to free expression. As article 19 of the United Nations Declaration of Human Rights states: "Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers."

Governments must embrace the rights of their citizens and non-citizens alike to share their voices, ideas, values, beliefs, and dreams without fear of persecution or violence. As citizens of the world with a shared humanity, we urge the government of Cuba to drop all charges against Tania Bruguera, Angel Santiesteban, and Danilo Maldonado "El Sexto," who are either imprisoned or facing imprisonment for doing what every person of the planet should be able to do: expressing themselves.

Title of Work:
#YoTambienExijo: A Restaging of Tatlin's Whisper #6

**Instructions**

For performance:
•No microphone is needed. Instead use a human microphone like the ones used in Occupy Wall Street.
•A small box (soapbox style) for the speaker to stand on.
•People are invited to speak for one minute about freedom of speech.
•Optional: If you want to you can include a WHITE dove, but do not keep the dove on the shoulder as this is extremely difficult. Each person can hold the dove in their hands, and hands it over to the next person. Have a few… just in case they escape.

For documentation:
•Please document events (either with still or video) and post to the Creative Time Facebook "event" at facebook.com/creativetime, as well as on personal and, preferably, institutional Twitter and Instagram accounts, using the hashtags #YoTambienExijo and #FreeTaniaBruguera. Please indicate where the performance occurred and when.

8 Quick Takeaways on Future of US-Cuba Relations from the Summit of the Americas

8 Quick Takeaways on Future of US-Cuba Relations from the Summit of the Americas

1. Embarrassing lack of tolerance and "civility" on part of Cuba's official civil society delegation (major contrast with Raul Castro's warm and respectful approach to Obama). Failed the test of tolerance but will have to learn as the days of the exclusive, official "Cuban delegation" representing the island at international events are over since the migration reform of 2013. Question: Cuba can open up to the US (and vice versa) but can it open up to ITSELF - listen to the diverse and often dissenting views and organizations of its emergent civil society?

2. Surprising personal regard Raul Castro expressed for Obama as "an honest man" who has "no responsibility for past US policy" - I loved when Raul admitted he had cut that part from his speech, then put it back, then cut it, & finally decided to include it and was "satisfied" with his decision. History is made in the details.

3. Obama's clear understanding of the key role of civil society and public support for Cuban civil society - expressed both in his terrific speech at the civil society forum and by meeting with Manuel Cuesta Morua & Laritza Diversent. Obama later stressed that these two leading Cuban dissidents support his "empowerment through engagement" policy.

4. Obama-Castro historic handshakes, joint press conference, & private meeting - "agree to disagree," "work together where we can with respect and civility," "everything on the table based on mutual respect," "patience x 2!" - Obama looking forward and not trapped by ideology or interested in re fighting Cold War battles that started before he was born (but appreciates lessons of history); Raul still passionate (and long-winded) about past US wrongs but admits that can disagree today but "we could agree tomorrow."

5. Obama's unequivocal clarification that "On Cuba, we are not in the business of regime change; we are in the business of making sure the Cuban people have freedom and the ability to shape their own destiny," stressing that "Cuba is not a threat to the United States."

6. Maduro/Venezuela issue did not steal the show as some had feared (or hoped); Maduro did not get support for his condemnation of US sanctions and even had to endure some countries expressed concern for his own jailing of dissidents.

7. Shift in the region away from ideology toward economic pragmatism fueled in part by China slow-down, Russia nose-dive, & Venezuela implosion. US ready to step in with strategic economic engagement and oil diplomacy - especially to Caribbean Basin (H/T to Andrés Oppenheimer).

8. Also, various economically and diplomatically powerful Latin American nations have big domestic corruption scandals (Brazil, Argentina, Chile) or violence and security issues (Mexico, Central America) that make them wary of any confrontation with the US (H/T to Andrés Oppenheimer).

Friday, April 10, 2015

A Taste of "Entrepreneurial Cuba" + Video

Last Thursday, April 2, Arch Ritter and I were welcomed to the Americas Society/Council of the Americas by Alana Tummino to give our first joint presentation of our new book "Entrepreneurial Cuba."

I'm proud to say that the event was sold out (even if it was free - along with a free lunch!) and Arch and I thoroughly enjoyed ourselves thanks to great moderation by Alana and many eager and incisive questions from the attendees.

The video of the event is here (beginning at 1:00).

ascoa on livestream.com. Broadcast Live Free

For those of you who were not able to make it, here is a special order form for the book at a big discount. Also, below I'm providing the preface to the book along with a link to chapter 1.

Declaración de Rosa María Payá en Cumbre de Panamá

Declaración de Rosa María Payá en Cumbre de Panamá, Abril 2015

https://m.youtube.com/watch?v=nts8sVmaLhg&feature=youtu.be

Buenos días.

Quería agradecerles a todos la disposición del diálogo. Venimos con la disposición del diálogo. Queríamos a escuchar a nuestros hermanos cubanos, que sabemos que están en las mismas condiciones que nosotros.

Les quiero pedir a todos perdón en nombre del pueblo cubano por lo que acaba de ocurrir en el salón. A pesar de lo que ustedes vieron, los cubanos somos un pueblo generoso, solidario. Incluso esas personas que estaban allí tampoco tienen derechos. Esas personas tampoco pueden decidir. Y probablemente tampoco decidieron estar allí. Son las aberraciones que se dan cuando uno vive en dictadura.

Mi padre, que fue asesinado en un atentado del gobierno cubano hace poco más de dos años, decía que los derechos no tienen color político. Las dictaduras tampoco tienen color político. Y nosotros estamos aquí hoy queriendo promover soluciones a un problema que ya no es sólo cubano, ni sólo venezolano. Es un problema regional, como el que acabamos de tener todos aquí. Porque todos aquí hemos sido afectados por una intolerancia que no compartimos.

Hay dos puntos que yo quisiera promover.

El primero nos está afectando en varios países de la región: es el tema de la impunidad. Vemos muchachos desapareciendo en México. Vemos fiscales que mueren el día antes de presentar la evidencia. Vemos niños asesinados en las calles de Caracas. Mi mejor amigo y mi padre fueron asesinados en un atentado hace dos años y medio, y ni siquiera tenemos el informe de la autopsia. La impunidad es un problema que nos está afectando a todos. Sabemos que también en Nicaragua, y en Guatemala. Quisiera que quedara asentado nuestro punto a favor de detener la impunidad y hacer un llamado de atención a la alta política de América Latina para detener esa impunidad y tomar medidas imparciales.

Mi segundo punto quizás pueda ser entendido como muy particular, porque tiene que ver con Cuba. Pero desde Cuba ha habido una marcada injerencia (también la habido desde otros países, como los Estados Unidos, pero yo soy cubana) y podemos detener la injerencia que en algunos lugares de América Latina, sobre todo en Venezuela, el gobierno cubano está implementando en estos momentos.

Mi punto es a favor del derecho a decidir de los cubanos. Los cubanos no deciden en elecciones libres y plurales hace más de 60 años. Les estamos pidiendo el apoyo al derecho a decidir de los cubanos en un plebiscito.
Dentro de dos días vendrá un general a conversar con los presidentes de América Latina: una persona que nunca ha sido escogida por el pueblo. También queremos oírlo, pero queremos que se escuche al pueblo. Por eso les pedimos apoyo para la realización de un plebiscito en Cuba y que se les pregunte a los cubanos si quieren un proceso de elecciones libres y plurales, si quieren el reconocimiento de los partidos políticos, si quieren acceso a los medios. Y si quieren este proceso en condiciones de imparcialidad.

Apoyar el derecho a decidir de los cubanos es también apoyar el derecho a decidir, el derecho al desarrollo y a la democracia de toda la región.

Muchas gracias.

Rosa María Payá Acevedo

Wednesday, April 8, 2015

Cuba's got the BnB, but do they have the Air?

The ad reads: "One giant leap for man's kindness" (above).
And: "The doors to 1,000 real Cuban homes are now open to you" (below).

I was awoken this Tuesday morning here in Miami, where I am on vacation, by a call from Andrea Hsu, a producer for NPR's afternoon flagship show "All Things Considered." It turns out she had seen the same full page Airbnb add on Sunday (above) that I had. However, while I saw mine in the Miami Herald, she saw hers in the Washington Post and told me there were similar ones in The New York Times and other U.S. newspapers over the weekend.

So I went to the WLRN studios in Downtown Miami to chat with Audie Cornish (really gotta love that name!) about what Airbnb's entry into Cuba means and how it will work given that making cashless payments via credit cards to Cuban homeowners in Cuba is not yet possible. Moreover, as the title to this post indicates, Cuba's got the BnB, but the "Air," not so much! In other words, a reservation system based on access to the Internet is less than ideal in a country where somewhere between 5-15% of the population has web access and very few of those have it from home.

Still, I told Audie that this development was not only a brilliant business move by Airbnb (Americans are eager to explore Cuba and Internet access there can only get better!) but also one of the few areas where there's an unequivocal win-win-win-win for the other parties involved.

That is, as I Tweeted earlier today:

(1) Cubans: Airbnb has developed a "workaround" to get cash payments sent to Cuban homeowners via a veteran Miami-based money transfer service;

(2) Americans: American travelers will have greater ability to meet real Cuban people in a more relaxed, authentic environment by staying with them in their own homes (and save some $);

(3) The US Gov: The arrangement is directly in line with the new Obama policy of greater citizen empowerment and people-to-people contacts (not to mention fully legal under new regulations published a few weeks ago); and

(4) The Cuban Gov: The past few months have shown that there are not enough hotel rooms on the island to handle the mad rush of arriving Yanks! (even if Cuba has been building them for more than 20 years with the help of many foreign partners) - thus making these entrepreneurs a key part of Cuba's economic opening and one whose growing wealth the government will have an incentive to tolerate.

If you've made it all the way to the end of this post, you deserve a prize. So, I'm providing a link to a paper I wrote in 2002 entitled, "Condemned to Informality: Cuba's Experiments with Self-Employment (The Case of the Bed and Breakfasts)," Cuban Studies 33, pp. 1-29.

Also, as a bit a lagniappe, here's a link to a related article I published in 2008 about Cuba's famed private home-based restaurants, aka, paladares. It is entitled, "Vale Todo: In Cuba’s Paladares, Everything is Prohibited but Anything Goes."

Tuesday, March 24, 2015

AS/COA hosts Arch Ritter & @ElYuma for lunch on April 2!

Entrepreneurial Cuba:
A Discussion on 
Cuba’s Emerging Non-
State Sector

AS/COA

In 2011, Cuban President Raúl Castro began the process of reforming policies toward entrepreneurs and small, private enterprises. Join Ted Henken and Archibald Ritter as they present their book Entrepreneurial Cuba: The Changing Policy Landscape,* which analyzes the evolution of Cuban policy since 1959. Henken and Ritter will discuss Cuba’s fledgling non-state sector, the underground economy, the new cooperative sector, Cuban entrepreneurs’ responses to the new business environment, and how Obama’s new policy of entrepreneurial engagement might impact Cuba’s “cuentapropistas.”
*Copies of the book will be available for purchase.
Speakers: 
  • Ted A. Henken, Professor of Sociology and Latin American Studies, Baruch College, CUNY
  • Archibald R.M. Ritter, Distinguished Research Professor, Department of Economics, Norman Paterson School of International Affairs, Carleton University, Ottawa, Canada
  • Alana Tummino, Policy Director, Americas Society/Council of the Americas; Senior Editor, Americas Quarterly (Moderator)
Registration Fee: This event is complimentary for all registrants. Prior registration is required.
Event Information: Sarah Bons | sbons@as-coa.org | 212-277-8363
Press: Adriana La Rotta | alarotta@as-coa.org | 212-277-8384
Cancellation: Contact Juan Serrano-Badrena atjserrano@counciloftheamericas.org before 3:00 p.m. on Wednesday, April 1, 2015

Thursday, February 19, 2015

La nueva política de Internet del gobierno cubano: Del "potro salvaje" al "caballo de Troya"?

En @14ymedio Renaldo Escobar (@rescobarcasas) escribe lo siguiente sobre la nueva política de Internet del gobierno cubano:

"La inmensa mayoría de los informáticos cubanos son jóvenes inclinados a la modernidad y se preocupan más por estar actualizados con las últimas novedades que de los potenciales peligros de que este 'potro salvaje' sea finalmente el caballo de Troya que permita a los cubanos acceder libremente a cualquier información y poder interactuar con el mundo exterior, sin intermediarios y sin miedos."

http://www.14ymedio.com/cienciaytecnologia/Proponen-creacion-organizacion-profesionales-informaticos_0_1728427144.html#.VOYH6irZX5c.twitter

Friday, February 13, 2015

FAQs from the DOS "Cuentapropista List" (Update)


Goods (few) and Services (many) Eligible for Importation to the United States from Cuba's Nascent Private Enterprise Sector

The "Cuentapropista Importation List" itself (technically known as the U.S. Department of State Section 515.582 List), is currently more a "list of exceptions" to the list of importable goods than a list of permissions (see below). On the bright side, the list of "importable" services is much more open-ended. A helpful Fact Sheet is also available at the DOS site.

Here is my favorite Q&A from the FAQs sheet:
Q: Will the Cuban government allow independent entrepreneurs to export to the United States?

A: We cannot predict what the Cuban government will or will not allow, but we sincerely hope that it makes this and other new opportunities available to Cuba's nascent private sector. This is another measure intended to support the ability of the Cuban people to gain greater control over their own lives and determine their country's future.

Indeed, the ball is now in Raúl's court and we will see if he can take this preliminary "yes" for an answer.

Mimi Whitefield has a good write up on the new list at the Miami Herald: "New import rules for Cuba represent historic change." Despite the hopeful title of the article, Whitefield does not ignore the unfortunate, "underwhelming" caveat that this opening is riddled with exceptions:
"But forget the artisanal cigars, home brew or even refurbished vintage cars. Tobacco, spirits and machinery are among the exceptions not eligible for import under the new rules.  
"Prepared food and beverages, textile and textile articles and animal products also aren’t eligible for import, cutting out important potential sales opportunities for Cuba’s cuentapropistas, the self-employed. For the record, imports of live animals, vegetables, chemical and mineral products, electrical equipment, telecom parts, articles made from nickel, zinc, copper and other non-precious metals and mechanical appliances aren’t permitted either.  
"Items that aren’t on the list of exceptions may be imported."  
For me, the three big takeaways are:

1. The list is purposely a "negative" one meaning that instead of listing what is permitted in exhaustive detail (as the GOC does with its list of licensable self-employed occupations), the DOS only lists what the exceptions are - hoping that this approach sends a message to Cuban entrepreneurs that they should use their imaginations, be encouraged to be creative, and think outside the box.

2. However, a big problem is that all imports into the U.S. are subject to tariffs and those from Communist countries like Cuba even more so, plus there are tons of things that remain off limits as indicated in the quote from Whitefield's article above. This part is quite disheartening. Along with the fact that agriculture is more or less off the table (for now). American companies may advocate for the ability to sell their wares and foodstuffs to Cuba, but few are demanding the right of Cuban entrepreneurs to compete as sellers in the U.S. market.

3. There is much more space in this opening for "importable" Cuban services and even products produced by Cuba's new non-agricultural co-operatives (note the "entities" language in the list). Also, those returning from Cuba to the U.S. with goods can go beyond the previously established $400 limit as long a the other goods were acquired from the private sector (and under a $800 total since that's when steep tariffs would kick in).

So while important in making a historic crack in the wall of the U.S. embargo, challenging the Cuban government to respond by broadening and deepening its initial micro-enterprise reforms between 2010-2014, and facilitating some trade with Cuba's emergent private sector, this is still quite a small, symbolic step that will have little impact on the ground in Cuba in the short term.

This is due to (1) the Cuban government's continued monopoly over imports and exports and (2) the limited authority the Obama administration has vis-a-vis trade since much of the economic embargo (and tariff restrictions for imports) remain in place preventing full engagement with Cuba's emerging private sector.

One silver lining is that the DOS sees this as a "living document" that they expect to expand over time as they get feedback from Cuba's private sector.

Tell your friends!