Monthly Archives: January 2016


The Office of Foreign Assets Control has announced changes this week amending regulations restricting exports and facilitating authorized travel between Cuba and the United States. Changes include allowing entry of U.S. and foreign air carriers into Cuba in the form of code sharing and leasing arrangements to facilitate the provision of carrier services between Cuba and the U.S., including entry into such arrangements directly with Cuban airlines. The agreement also allows for the removal of restrictions on payment and financing terms for authorized imports and exports except agricultural commodities and U.S. depository institutions, which will be allowed to provide Cuban financing. The United States will also be allowed to export and re-export other commodities, including software, telecom items and certain agricultural items. Restrictions on travel for professional meetings and public performances have been eased as well, although travel for tourist activities continues to be prohibited. This announcement follows actions by the U.S. State Department last month that allowed Cuba and the United States to reach a new bilateral air services agreement for air services after three days of technical talks on civil aviation held in Washington D.C. Immediately following the announcement, American Airlines, which has operated charter service to Cuba since 1991, announced plans to submit a U.S. – Cuba service proposal to the U.S. DOT to begin scheduled service from Miami International Airport and its other service hubs as early as next year. United Airlines, as well as JetBlue Airways, Southwest Airlines and Spirit Airlines have also expressed interest in flying to Cuba as soon as all regulatory requirements are fulfilled.

If you have any questions, please contact Evelyn Sahr (, 202-659-6622), Drew Derco (, 202-659-6665), or Reese Davidson (, 202-659-6633).

REMINDER: Part 382 Annual Disability Reports due on January 25, 2016

Pursuant to 14 C.F.R. Part 382, covered U.S. and foreign air carriers that conduct passenger service to, from, or within the United States must record and categorize disability-related complaints they receive during each calendar year.  At the end of the year, carriers are required to submit an annual report of the complaints they received to the Department’s Aviation Consumer Protection Division on or before the last Monday in January.  This year’s report, covering calendar year 2015, is due on January 25, 2016.

The report must be submitted by the carrier’s authorized representative electronically at Please note, carriers that did not receive any written disability-related complaints in calendar year 2015 are still required to file a report showing no complaints.  Penalties for non-compliance can be severe (up to $27,500 per day per violation) and the Aviation Enforcement Office has taken action against a number of carriers in the past for failing to comply with these requirements.

If you have any questions, or need assistance with filing your carrier’s report, please contact either Evelyn Sahr at (202-659-6622) or Drew Derco at (202-659-6665).