Cuba Sanctions Work Two Ways—Creating Risk on Both Ends of a Transaction

U.S. Cuba policy splits into separate legal channels. OFAC licenses permit American tourists to pay for hotels legally. But Helms-Burton's Title III—enforced since 2019 after decades of pause—lets U.S. nationals sue foreign operators profiting from property Cuba seized after 1959. An American's payment clears under one law; the foreign hotel faces U.S. court liability under another. Each side requires separate legal analysis.