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National Security Presidential Memorandum (NSPM)

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On February 6, 2025, the US State Department reversed the Biden Administration’s revocation of President Trump’s National Security Presidential Memorandum 5 of June 16, 2017 and recreated the Cuba Restricted List (“CRL” or “List”), which identifies entities and subentities that are controlled by, or acting on behalf of, the Cuban military, intelligence, or security services or personnel. The US State Department also added a Cuban remittance provider to the CRL, effective March 10, 2025. For…

On April 19, the US Government issued a fact sheet outlining a new policy (the ā€œNew UAS Policyā€) on exports of US-origin unmanned aerial systems (ā€œUASā€) and a new National Security Presidential Memorandum (ā€œNSPMā€) updating the United States Conventional Arms Transfer Policy (the ā€œNew CAT Policyā€). These changes do not directly impact the export licensing requirements on UAS under the International Traffic in Arms Regulations (ā€œITARā€) or the Export Administration Regulations (ā€œEARā€). However, according to statements made in a press briefing on these developments, the new policies reflect the Trump Administration’s interest in enabling US manufacturers of UAS to ā€œlevel the playing fieldā€ and increase exports of these products to US allies and partners. They also evidence a broader effort to increase considerations of economic interests in arms transfer decisions.