President Donald J. Trump signs the National Security Presidential Memorandum on Strengthening the Policy of the United States' Toward Cuba, June 16, 2017
Co-authored by Marguerite Rose Jiménez
There is a poison pill hidden in President Donald Trump’s National Security Presidential Memorandum (NSPM) on Cuba that could deprive over a million Cuban families of access to remittances from their relatives abroad—a declaration of economic war on the very people that Trump claims his policy will empower.
Section 3(d) of the NSPM redefines “prohibited officials of the Government of Cuba” expansively, potentially including almost a quarter of Cuba’s entire labor force. The significance: Cubans who are “prohibited” are not allowed to receive payments from U.S. persons, and that includes remittances (Cuban Assets Control Regulations, §515.570). Sec. 3.(a)(iii)(g) of the NSPM would seem to protect remittances, but it conflicts with the existing CACR ban on payments to prohibited officials.
The previous regulatory definition of prohibited officials was very narrow, limited to members of the Council of Ministers and flag officers of the Revolutionary Armed Forces. The new definition proposed by President Trump includes hundreds of senior officials in every government agency, thousands of ordinary Cubans who volunteer as leaders of their local Committees for the Defense of the Revolution, and—most importantly― every employee of the Ministry of the Revolutionary Armed Forces (MINFAR) and Ministry of the Interior (MININT).
MINFAR has some 60,000 active duty troops and MININT has some 35,000 police and Border Guards, and that’s not counting their civilian employees. Military service is compulsory for both men and women, so almost every family on the island will be affected by this new definition at some point.
More importantly, according to the U.S. government’s Cuba Broadcasting service, over a million Cubans are employed by the two big holding companies, GAESA and CIMEX, that report to MINFAR. If all these people are now to be considered “prohibited officials,” then a quarter of the Cuban labor force will no longer be eligible to receive remittances.
For Cuban state employees who are paid an average salary equivalent to about $25 a month, cutting them off from family remittances will have a devastating impact on their standard of living. By what possible logic can a clerk at GAESA, a truck driver at CIMEX, or a private in the Cuban army be defined as an “official” important enough to be prohibited from receiving help from their family abroad?
The alleged premise of Trump’s policy is to empower the Cuban people by directing U.S. funds to them, rather than to the Cuban government. Remittances are the very best way to do that because the dollars go directly to family on the island, at a rate of about $3 billion annually.
President Trump could have imposed limits on remittances directly and openly, as previous presidents have done, but that would have been very unpopular in the Cuban American community, so instead he has disguised a potentially massive cut behind the small print of an obscure regulation. Now it is up to the Treasury Department’s Office of Foreign Assets Control to write the new regulations in a way that averts this travesty.
