Timothy O'Toole commented on the effect of relaxed Cuba trade restrictions on U.S. banks, which remains unclear. "The press surrounding President Obama's announcement of changes to the Cuba policy has been a lot more dramatic than the changes themselves," O'Toole said, adding that there continues to be a huge number of restrictions on U.S. corporations and banks who want to do business in Cuba and banks are still quite limited in what they can finance.

"My clients have two concerns," O'Toole said. "One is that they don't want to be late to the Cuba trade. The countervailing concern is the continued risk from violating the embargo, particularly given the political uncertainty surrounding how long any changes in the Cuba policy will last. So far, I think the latter concern about continued risk is prevailing, and caution is winning the day. But I think each step being taken by regulators to encourage additional Cuba trade and travel is starting to convince companies and individuals that a new day is really here, and if they wait any longer they'll be late to the party."