Yep, you are probably right. Circumvented probably the wrong word. Mitigated or neutralised might be better words. OFAC is very US-centric (Dept of Treasury makes the rules, and they expect the rest of the world to fall in line), whereas we "normal" people (the rest of the world) take a more sensible approach to sanctions (DFAT does not include Cuba in their sanction list, for example). Kinda like the FATCA versus CRS argument (US "dictated" that we must all follow FATCA - to improve IRS effectiveness - and Europe then reacted with CRS).
I guess I am just happy to see developing nations such as Cuba kick off the shackles of politics which is 50 years out of date. Why should Mr and Mrs Rodriguez continue to suffer just because Kennedy and Khrushchev couldn't agree on who Castro invited to his birthday party 60 years ago (ok, slight simplification of the issue). There are those out there, of course (no names) who still believe it is 1961 and still express a bias against Cuba. Thankfully, not Melbana.
Regards
Kit
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