Mr. Sanctions

Category: Cuba

  • For Non-Lawyers: OFAC’s Cuba Sanctions Practitioners Guides

    In English:

    Cuba_Sanctions_Practitioners_GuideDownload

    and Spanish:

    Cuba_Sanciones_Guia_Profesionales_ESDownload

    And already on the Resources page for Practitioners Guides.

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  • In Plain Language: OFAC’s Cuba Sanctions Guides

    In English:

    Cuba_Sanctions_Plain_Language_GuideDownload

    and Spanish:

    Cuba_Sanciones_Guia_Accesible_ESDownload

    And these are already on the Resources pages.

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  • May 18, 2026: Better Late than Never – State Department Press Release and Fact Sheet

    These releases, which both arrived after 5 PM Eastern, are in relation to today’s OFAC release.

    Here are the press release:

    Further U.S. Sanctions on Cuban Regime Elites

    PRESS STATEMENT

    MARCO RUBIO, SECRETARY OF STATE

    MAY 18, 2026

    The Trump Administration continues to take decisive action to protect U.S. national security and deprive Cuba’s communist regime and military of access to illicit assets.  Today, pursuant to President Trump’s Executive Order 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” I designated 11 Cuban regime elites and three government organizations, including government officials and military figures associated with Cuba’s security apparatus, many of whom are responsible for or have been involved in repressing the Cuban people.   

    These sanctions advance the Trump Administration’s comprehensive campaign to address the pressing national security threats posed by Cuba’s communist regime and to hold accountable both the regime and those who provide it material support.  Regime-aligned actors such as those designated today bear responsibility for the suffering of the Cuban people, the failing Cuban economy, and the exploitation of Cuba for foreign intelligence, military, and terror operations.  Today’s designations further restrict the Cuban regime’s ability to suppress the will of the Cuban people.  Additional sanctions actions can be expected in the following days and weeks.    

    The Department’s action is being taken pursuant to Executive Order (E.O.) 14404, which authorizes sweeping sanctions on Cuba, including persons who support the Cuban regime’s security apparatus and those responsible for repression in Cuba and threats to U.S. national security. This action also furthers both Executive Order 14380, “Addressing Threats to the United States by the Government of Cuba”and National Security Presidential Memorandum 5 (NSPM-5), which directs the Executive Branch to improve human rights, encourage the rule of law, foster free markets and free enterprise, and promote democracy in Cuba. See related Fact Sheet. 

    and the fact sheet:

    Sanctions to Counter Threats Posed by the Cuban Regime

    FACT SHEET

    OFFICE OF THE SPOKESPERSON

    MAY 18, 2026

    Today, the Department of State is sanctioning 11 Cuban regime-aligned actors and three entities in furtherance of the Trump Administration’s comprehensive campaign to address the pressing national security threats posed by Cuba’s communist regime and hold accountable the regime and those who provide it material or financial support.     

    For more than 60 years, the Cuban regime has prioritized its Communist ideology and personal wealth over the well-being of its own citizens while allowing for the exploitation of Cuba for foreign intelligence, military, and terror operations.  The United States will continue to take action to counter the Cuban regime, those furthering its goals, and those abroad enabling the elites to profit while the Cuban people suffer.  

    Today, all Department of State targets are being sanctioned pursuant to Executive Order (E.O.) 14404, which authorizes sanctions on persons determined to meet specified criteria related to repression in Cuba and threats to U.S. national security.   

    Taking Action Against the Cuban Regime 

    The Department of State is designating 11 regime-aligned elites associated with Cuba’s security apparatus, as well as three Cuban government bodies.  

    The following entities are being designated pursuant to Section 2 (a)(i)(F) of E.O. 14404 for being a political subdivision, agency, or instrumentality of the Government of Cuba: 

    • The MINISTRY OF INTERIOR OF CUBA (MININT), which is an agency of the Government of Cuba responsible for Cuba’s internal security, to include controlling Cuba’s police, internal security forces, intelligence agencies, and the country’s prison system.  Today’s action expands upon MININT’s prior designation pursuant to E.O. 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act;  
    • The POLICIA NACIONAL REVOLUCIONARIA (PNR), which is a police force under MININT accused of operating mobile prisons and violent suppression of protests.  Today’s action expands upon the PNR’s prior designation pursuant to E.O. 13818; and  
    • The DIRECTORATE OF INTELLIGENCE OF CUBA (DGI), which is the primary intelligence agency of the Government of Cuba under MININT. 

    The following actors are being designated pursuant to Sec. 2 (a)(i)(E) of E.O. 14404 for being or having been a leader, official, senior executive officer, or member of the board of directors of the Government of Cuba or an entity whose property or interests in property are blocked pursuant to E.O. 14404: 

    • EDDY MANUEL SIERRA ARIAS (SIERRA), the Chief of the General Directorate of the PNR, which is being concurrently designated pursuant to E.O. 14404.  Today’s designation of SIERRA builds upon his prior designation pursuant to E.O. 13818; 
    • OSCAR ALEJANDRO CALLEJAS VALCARCE (CALLEJAS), the Chief of the Political Directorate of the concurrently designated MININT and the former Director of the also concurrently designated PNR.  Today’s designation of CALLEJAS expands upon his prior designation pursuant to E.O. 13818; 
    • ROSABEL GAMON VERDE, the Minister of Justice of Cuba;   
    • JOAQUIN QUINTAS SOLA, the Deputy Minister of Cuba’s Revolutionary Armed Forces; 
    • JUAN ESTEBAN LAZO HERNANDEZ, the President of Cuba’s National Assembly for People’s Power; 
    • VICENTE DE LA O LEVY, the Minister of Energy and Mines of Cuba; 
    • MAYRA AREVICH MARIN, the Minister of Communications of Cuba;  
    • JOSE MIGUEL GOMEZ DEL VALLIN, the Chief of Staff of Military Counterintelligence; 
    • RAUL VILLAR KESSELL, the Chief of the Central Army of Cuba;  
    • ROBERTO TOMAS MORALES OJEDA, a member of the Political Bureau and Secretary of the Organization of the Central Committee of the Communist Party of Cuba; and 
    • EUGENIO ARMANDO RABILERO AGUILERA, the Chief of the Eastern Army of Cuba. 

    Sanctions Implications  

    As a result of today’s sanctions-related actions, and in accordance with Executive Order 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy,” all property and interests in property of the designated persons described above that are in the United States or in possession or control of U.S. persons are blocked and must be reported to the Department of the Treasury’s Office of Foreign Assets Control (OFAC).  Additionally, all entities that are owned individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. 

    All transactions and dealings by U.S. persons or persons within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt.  These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.  Foreign persons that engage in transactions with persons designated pursuant to E.O. 14404 – or that operate in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, as identified in E.O. 14404 – are themselves at risk of sanctions.  Non-U.S. persons, including foreign financial institutions, should proceed with caution in any dealings with a party sanctioned under this authority.  Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.  All property and interests in property of persons that are blocked pursuant to the CACR continue to be blocked.  The CACR prohibits persons subject to U.S. jurisdiction from dealing in property in which Cuba or a Cuban national has an interest, unless authorized or exempt. 

    The power and integrity of U.S. government sanctions derive not only from the U.S. government’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law.  The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.    

    Petitions for removal from the SDN List may be sent to:  OFAC.Reconsideration@treasury.gov.  Petitioners may also refer to the Department of State’s Delisting Guidance page.  

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  • May 18, 2026: OFAC Updates, Part 2: The Cuba Designations*

    Cuba Designations and Designations Updates; Issuance of Russia-related General License

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: [CUBA-EO14404]  Cuba-related sanctions pursuant to Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy”

    AREVICH MARIN, Mayra

    • Address: Cuba
    • DOB: 1966
    • POB: Havana, Cuba
    • Nationality: Cuba
    • Gender: Female
    • Party Type: Individual

    Supplemental Information: Mayra Arevich Marin has served as Cuba’s Minister of Communications since April 2021, appointed by President Miguel Díaz-Canel. Prior to that role she served as Executive President of ETECSA (Empresa de Telecomunicaciones de Cuba), Cuba’s state telecommunications monopoly, from 2011 to 2021. She is a telecommunications engineer who graduated in 1989 and holds a master’s degree in telematics from the Universidad Central de Las Villas Marta Abreu. She is a member of the PCC Central Committee and a deputy in the National Assembly of People’s Power.

    DE LA O LEVY, Vicente

    • Address: Havana, Cuba
    • DOB: 25 Apr 1962
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Vicente De La O Levy is Cuba’s Minister of Energy and Mines, appointed in October 2022. A mechanical engineer by training, he spent his career in Cuba’s state energy sector, serving as Vice Minister of Sidero-Mechanics (1995–2001), President of ACINOX (2001–2003), and Director-General of Cuba’s state electricity utility (Unión Eléctrica de Cuba, 2005–2010). From 2010 to 2013 he led Cuba’s Energy Mission in Venezuela before serving as President of the Electronics Group until October 2022. In May 2026 he publicly acknowledged in a televised appearance that Cuba’s fuel reserves for electricity generation had been fully exhausted.

    GAMON VERDE, Rosabel

    • Address: Cuba
    • DOB: 09 Feb 1973
    • POB: Havana, Cuba
    • Nationality: Cuba
    • Gender: Female
    • Party Type: Individual

    Supplemental Information: Rosabel Gamon Verde is Cuba’s Minister of Justice. She previously served as First Deputy Minister of Justice, in which capacity she represented Cuba at the 33rd session of the UN Commission for the Prevention of Crime and Criminal Justice in Vienna in May 2024, addressing Cuba’s anti-trafficking efforts. As Minister of Justice she has publicly defended government positions on law enforcement matters, including appearing alongside the head of MININT’s anti-narcotics directorate at a February 2026 press conference arguing that Cuba should be seen as a partner, not a threat, in counter-narcotics efforts.

    GOMEZ DEL VALLIN, Jose Miguel

    • Address: Las Tunas, Cuba
    • DOB: 06 Aug 1960
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Jose Miguel Gomez del Vallin is a Major General (General de División) in Cuba’s Revolutionary Armed Forces (FAR), serving as head of the FAR’s Directorate of Military Counterintelligence (Contrainteligencia Militar, CIM). He holds a law degree (Licenciado en Derecho) and has served in counterintelligence roles across all three of Cuba’s armies (Eastern, Central, and Western). He served an internationalist mission in Angola from 1987 to 1989. He has been a member of the PCC Central Committee since 2021 and a National Assembly deputy since 2023, having served as a delegate to the 6th, 7th, and 8th PCC Congresses.

    LAZO HERNANDEZ, Juan Esteban

    • Address: Cuba
    • DOB: 26 Feb 1944
    • POB: Jovellanos, Provincia de Matanzas, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Juan Esteban Lazo Hernandez is the President of Cuba’s National Assembly of People’s Power (Asamblea Nacional del Poder Popular, ANPP), a position he has held since February 2013. As ANPP president he also chairs the Council of State—the standing body that exercises legislative authority between Assembly sessions under the 2019 constitution—which he has headed since 2019. He joined the Communist Party in 1963 and has been an ANPP deputy since 1981. He is a longtime member of the PCC Politburo, joining it in 2003 per official Cuban sources, and is one of its longest-serving current members. His formal role at the head of the National Assembly made him the presiding officer over the legislative ratification of Miguel Díaz-Canel’s elections to the presidency in 2018 and 2023.

    MORALES OJEDA, Roberto Tomas

    • Address: Cienfuegos, Cuba
    • DOB: 15 Jun 1967
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Roberto Tomas Morales Ojeda is a member of both the PCC Politburo and Secretariat, holding the cadres portfolio as Secretary of Organization and Cadre Policy of the PCC Central Committee since 2021—the role responsible for senior party appointments across Cuba. He previously served as a Vice President of Cuba (2018–2019) and as Minister of Public Health (2010–2018), during which he oversaw the international expansion of Cuba’s medical-mission program, one of the regime’s principal sources of hard currency. A physician who graduated in 1991, he also holds a master’s degree in public health. He has been widely described by analysts and Cuban opposition media as a leading candidate to succeed President Miguel Díaz-Canel.

    QUINTAS SOLA, Joaquin

    • Address: Colon, Matanzas, Cuba
    • DOB: 24 Sep 1938
    • POB: Santiago de Cuba, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Joaquin Quintas Sola holds the rank of Army Corps General (General de Cuerpo de Ejército) in Cuba’s Revolutionary Armed Forces and serves as Deputy (Vice) Minister of the FAR and Head of the Central Strategic Region. He is a Hero of the Republic of Cuba and has been a PCC Central Committee member since 1980. He joined the July 26 Movement in late 1956, participated in the final stages of the Cuban Revolution, and served two internationalist missions in Angola. He studied at the Soviet K. Voroshilov Military Academy and commanded the Central Army for approximately two decades before his current vice-ministerial role. He has also represented Cuba’s military in engagements with foreign armed forces, including supervising military exercises in Venezuela and leading official delegations to South Africa.

    RABILERO AGUILERA, Eugenio Armando

    • Address: Cuba
    • DOB: 06 Nov 1964
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Eugenio Armando Rabilero Aguilera is a Major General (General de División) in Cuba’s Revolutionary Armed Forces, serving as Head of the Eastern Army (Ejército Oriental) since March 2024. The Eastern Army is responsible for the defense of Cuba’s six eastern provinces (Camagüey, Las Tunas, Holguín, Granma, Santiago de Cuba, and Guantánamo). He is a member of the PCC Central Committee. He served an internationalist mission in Angola from 1987 to 1989 as a platoon commander and holds the qualification of Tank Tactical Command Engineer. He has received multiple military decorations including the “Ignacio Agramonte” and “Combatiente Internacionalista” medals.

    VILLAR KESSELL, Raul

    • Address: Ciego de Avila, Cuba
    • DOB: 04 Aug 1965
    • POB: Bahia Honda, Artemisa Province, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Raul Villar Kessell is a Major General (General de División) in Cuba’s Revolutionary Armed Forces, serving as Head of the Central Army (Ejército Central). He was added to the PCC Central Committee in July 2025. He has notable ties to China’s military establishment, having completed graduate studies at the National Defense University of the People’s Republic of China, distinguishing him from most senior FAR officers who trained in Soviet-era academies. Analysts describe him as an emerging figure within Cuba’s military hierarchy, with strong strategic and theoretical training and significant connections within the Chinese military.

    The following entity has been added to OFAC’s SDN List:

    OFAC Program: [CUBA-EO14404]  Cuba-related sanctions pursuant to Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy”

    DIRECTORATE OF INTELLIGENCE OF CUBA (Latin: DIRECCIÓN DE INTELIGENCIA)

    • AKA:
      • DIRECCION GENERAL DE INTELIGENCIA
      • DGI
      • G2
    • Address: Cuba
    • Organization Established Date: 06 Jun 1961
    • Target Type: Government Entity

    Supplemental Information: The Directorate of Intelligence of Cuba (officially Dirección de Inteligencia, DI) is Cuba’s primary state intelligence agency, responsible for foreign intelligence collection. Commonly known as G2, it was called the Dirección General de Inteligencia (DGI) until 1989. It was founded in late 1961 under Cuba’s Ministry of the Interior, established with significant assistance and training from the Soviet KGB. The agency has six divisions across operational and support categories. During the Cold War it worked closely with the KGB, supported revolutionary movements in Latin America and Africa, and conducted espionage directed at the United States. Former U.S. Senate investigators and other sources have linked the DGI to support for Puerto Rican separatist groups and other foreign extremist networks. Its headquarters are located at Linea and A, Vedado, Havana.

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    • OFAC Programs:
      • [GLOMAG]  Global Magnitsky Sanctions Regulations, 31 C.F.R. part 583; Executive Order 13818, “Blocking the Property of Persons Involved in Serious Human Rights Abuse or Corruption”
      • [CUBA-EO14404]  Cuba-related sanctions pursuant to Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy”

    CALLEJAS VALCARCE, Oscar Alejandro

    • Address: Goycuria #119, 10 Octubre, Havana, Cuba
    • DOB: 19 Sep 1957
    • POB: Havana, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Passport: A006951 (Cuba) expires 18 Jul 2027
    • National ID No.: 57091910348 (Cuba)
    • Party Type: Individual
    • Linked To: POLICIA NACIONAL REVOLUCIONARIA

    Supplemental Information: Oscar Alejandro Callejas Valcarce served as Director of Cuba’s National Revolutionary Police (Policía Nacional Revolucionaria, PNR). He holds the rank of Brigadier General (General de Brigada) in the Cuban Revolutionary Armed Forces. He was added to the PCC Central Committee in July 2025. His original GLOMAG designation reflected his leadership role in the PNR in connection with human rights abuses; this update adds the CUBA-EO14404 designation and removes the unlabeled position field from his SDN listing.

    List of Changes:

    • Position:
      • Deleted: Director, Policia Nacional Revolucionaria
    • Program Tags:
      • Added: [CUBA-EO14404]

    MINISTRY OF INTERIOR OF CUBA

    • AKA:
      • MINISTERIO DEL INTERIOR
      • MININT
    • Address: Aranguren and Carlos Manuel de Cespedes, Havana, Cuba
    • Organization Established Date: Jun 1961
    • Target Type: Government Entity

    Supplemental Information: The Ministry of Interior of Cuba (Ministerio del Interior, MININT) is Cuba’s primary internal security ministry, established in June 1961. It oversees state security, the National Revolutionary Police, immigration, the civil registry, and the prison system. It was originally designated under Global Magnitsky in connection with serious human rights abuses. This update changes its primary SDN List name (appending “OF CUBA”), adds a Target Type field, and adds the CUBA-EO14404 designation.

    List of Changes:

    • Primary Name:
      • Changed: MINISTRY OF INTERIOR to: MINISTRY OF INTERIOR OF CUBA
    • Target Type:
      • Added: Government Entity
    • Program Tags:
      • Added: [CUBA-EO14404]

    POLICIA NACIONAL REVOLUCIONARIA

    • AKA: NATIONAL REVOLUTIONARY POLICE
    • Address: Manzana que ocupan las calles Cuba, Tacon y Chacon, La Habana Vieja, Havana, Cuba
    • Organization Established Date: 05 Jan 1959
    • Target Type: Government Entity
    • Linked To: MINISTRY OF INTERIOR OF CUBA

    Supplemental Information: Cuba’s National Revolutionary Police (Policía Nacional Revolucionaria, PNR) is the country’s national law enforcement agency, established January 5, 1959, and subordinate to the Ministry of the Interior. It was originally designated under Global Magnitsky in connection with human rights abuses in Cuba. This update adds the English AKA “NATIONAL REVOLUTIONARY POLICE,” adds an Organization Established Date of 05 Jan 1959, updates the Linked To reference to the now-renamed MINISTRY OF INTERIOR OF CUBA, and adds the CUBA-EO14404 designation.

    List of Changes:

    • AKA:
      • Added: NATIONAL REVOLUTIONARY POLICE
    • Organization Established Date:
      • Added: 05 Jan 1959
    • Program Tags:
      • Added: [CUBA-EO14404]
    • Linked To:
      • Changed: MINISTRY OF INTERIOR to: MINISTRY OF INTERIOR OF CUBA

    SIERRA ARIAS, Eddy Manuel

    • Address: Calle 206A, No. 2119B, Entre 21 y 23, Atabey, Playa, Havana, Cuba
    • DOB: 03 Sep 1971
    • POB: Holguin, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Passport: A008237 (Cuba) expires 20 Apr 2027
    • National ID No.: 71090325982 (Cuba)
    • Party Type: Individual
    • Linked To: POLICIA NACIONAL REVOLUCIONARIA

    Supplemental Information: Eddy Manuel Sierra Arias served as Deputy Director of Cuba’s National Revolutionary Police (Policía Nacional Revolucionaria) at the time of his original GLOMAG designation. No additional reliable public information beyond his role in PNR leadership is available. This update adds the CUBA-EO14404 designation and removes the unlabeled position field from his SDN listing.

    List of Changes:

    • Position:
      • Deleted: Deputy Director, Policia Nacional Revolucionaria
    • Program Tags:
      • Added: [CUBA-EO14404]

    Mr. Sanctions’ Notes:

    • The title of the Recent Actions page only mentions the Cuba Sanctions program. However, as you may have noticed, updated records also include the Global Magnitsky program.
    • There was no Treasury or State Department press releases provided. So, I asked Claude to boil the ocean looking for supplemental info about the parties mentioned in the update. the list of those sources is below.

    Sources:

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  • May 7, 2026: OFAC Update, Part 2: The first Cuba GL I can remember, and 6 new FAQs

    Here it is: Cuba General License 1 (Transactions Authorized Pursuant to the Cuban Assets Control Regulations):

    cuba_gl1Download

    and Frequently Asked Questions 1251-1256:

    1256. Are all persons that operate or have operated in the five sectors of the Cuban economy identified in E.O. 14404 sanctioned by OFAC under E.O. 14404?  

    No. E.O. 14404 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, or the Secretary of State, in consultation with the Secretary of the Treasury, to impose blocking sanctions on any foreign person determined to operate or have operated in the following sectors of the Cuban economy: (1) energy; (2) defense and related materiel; (3) metals and mining; (4) financial services; and (5) security. E.O. 14404 also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to determine that the prohibitions in section 2(a)(i)(A) of E.O. 14404 apply to additional sectors of the Cuban economy.

    The identification of these sectors exposes foreign persons that operate or have operated in such sectors to sanctions risk; however, it does not automatically impose sanctions on all persons who operate or have operated in those sectors. Only foreign persons determined pursuant to E.O. 14404 to operate or have operated in an identified sector are subject to sanctions under this criterion.

    Persons should also note that E.O. 14404 is separate from the Cuban Assets Control Regulations (CACR), 31 CFR part 515. A person that is not sanctioned pursuant to E.O. 14404 may still be subject to CACR prohibitions or restrictions. For further information regarding the CACR prohibitions, please see FAQs 1252, 1254, and 1255.

    Released on May 07, 2026

    Cuba Sanctions

    1255. Are persons blocked pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, automatically blocked pursuant to the E.O. 14404?  

    No. Persons blocked or otherwise identified pursuant to the CACR are not automatically blocked pursuant to the E.O. 14404. The CACR and E.O. 14404 are separate sanctions authorities. E.O. 14404 separately authorizes the imposition of blocking sanctions and certain less-than-blocking sanctions against foreign persons determined to meet one or more of the criteria in E.O. 14404. Persons sanctioned under the CACR are only subject to sanctions under E.O. 14404 if such persons are separately determined by the Secretary of the Treasury or the Secretary of State to meet the criteria under E.O. 14404.

    Persons listed on OFAC’s Specially Designated Nationals and Blocked Persons List may be identified under one or more sanctions authorities.

    Released on May 07, 2026

    Cuba Sanctions

    1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA? 

    Generally, yes, but the U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50 percent or greater interest, through June 5, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.

    Foreign persons unable to wind down transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50 percent or greater interest, before June 5, 2026, are encouraged to contact the OFAC Compliance Hotline.

    Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with GAESA, a Cuban military-controlled entity, absent OFAC authorization. GAESA has been identified on the List of Specially Designated Nationals and Blocked Persons (SDN List) and the State Department-administered Cuba Restricted List since December 21, 2020. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving GAESA, including in connection with a foreign person’s wind down of activities with GAESA, unless separately authorized by OFAC.

    Released on May 07, 2026

    Cuba Sanctions

    1253. What does Cuba-related General License (GL) 1, “Transactions Authorized Pursuant to the Cuban Assets Control Regulations,” authorize?  

    On May 7, 2026, OFAC issued Cuba-related GL 1, authorizing all transactions prohibited by E.O. 14404 where such transactions are authorized or exempt under the Cuban Assets Control Regulations, 31 CFR part 515 (CACR).

    GL 1 includes transactions authorized by either general or specific license issued pursuant to the CACR. GL 1 is intended to ensure activity authorized or exempt under the CACR is not interrupted if a foreign person already blocked or otherwise identified under the CACR is also blocked pursuant to E.O. 14404, such as Grupo de Administración Empresarial S.A. (GAESA). In such cases, no additional OFAC authorization beyond GL 1 would be required to engage in CACR-authorized activities.

    GL 1 does not expand the scope of any authorization or exemption under the CACR. Any transaction must continue to comply with all relevant conditions and limitations as provided in the CACR to be authorized under GL 1. As with all OFAC GLs, GL 1 is “self-executing,” meaning that persons who assess that their transactions fall within the scope of the authorization may proceed without further assurance from OFAC. Transactions prohibited by E.O. 14404 require additional OFAC authorization if not authorized or exempt under the CACR.

    Released on May 07, 2026

    Cuba Sanctions

    1252. Does E.O. 14404 alter U.S. sanctions on Cuba pursuant to the Cuban Assets Control Regulations (CACR)?  

    No. All existing prohibitions and authorizations pursuant to the CACRremain in effect.

    E.O. 14404 was issued pursuant to the International Emergency Economic Powers Act (IEEPA), and is distinct from the CACR, which is issued pursuant to the Trading with the Enemy Act (TWEA), among other statutes. These authorities function in parallel. E.O. 14404 establishes the authority for a new Cuba-related sanctions program that includes blocking sanctions and certain less-than-blocking sanctions against foreign persons determined to meet one or more of the criteria in E.O. 14404.

    Simultaneously, OFAC continues to administer the CACR, including its prohibitions, authorizations, and exemptions. OFAC maintains the authority to identify certain persons on the List of Specially Designated Nationals and Blocked Persons (SDN List) under the CACR, including persons acting for or on behalf of the Government of Cuba. However, the CACR continues to operate as a jurisdictional sanctions program focused specifically on Cuba and Cuban nationals.

    Furthermore, Sections 2(b) and 4(c) of E.O. 14404 state that the relevant prohibitions found in E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR.

    Released on May 07, 2026

    Cuba Sanctions

    1251. What does Executive Order (E.O.) 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy,” do? 

    E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, “Addressing Threats to the United States by the Government of Cuba.” E.O. 14404authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on foreign persons determined to be involved in specified harmful activities related to Cuba, including:

    • operating, or having operated in identified sectors of the Cuban economy (e.g., Cuba’s energy, defense and related materiel, metals and mining, financial services, and security sectors);
    • acting for or on behalf of, or providing support to, the Government of Cuba or persons blocked pursuant to E.O 14404; and 
    • being responsible for or complicit in serious human rights abuse or corruption related to Cuba.

    E.O. 14404 establishes a new Cuba-related sanctions program under the International Emergency Economic Powers Act (IEEPA) that is separate from, and in addition to, the Cuban Assets Control Regulations (CACR), 31 CFR part 515. All existing CACR prohibitions and authorizations remain in effect. E.O. 14404 also expressly states that prohibitions within and actions taken pursuant to E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR. Additionally, on May 7, 2026, OFAC issued Cuba-related General License 1, “Transactions Authorized Pursuant to the Cuban Assets Control Regulations,” authorizing all transactions prohibited by E.O. 14404 where transactions are authorized or exempt under the CACR. See FAQ 1253 for additional information.

    While the United States has long maintained sanctions on Cuba and Cuban nationals pursuant to the CACR, E.O. 14404 broadens U.S. sanctions on Cuba to include authorizing sanctions on non-Cuban foreign persons for providing support to Cuba and on foreign financial institutions for conducting or facilitating significant transactions involving persons blocked pursuant to E.O. 14404. Foreign persons, including foreign financial institutions, should be aware of the new sanctions risk for engaging in certain conduct with Cuba as outlined in E.O. 14404.

    Released on May 07, 2026

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  • May 7, 2026: OFAC Update Part 1: Counter-Terror, Iran, Cuba Designations & Cuba updates

    Counter Terrorism and Iran-related Designations; Cuba Designation and Designations Updates; Issuance of Cuba-related General License and Frequently Asked Questions

    Treasury Press Release: Economic Fury Targets Iraqi Oil Official, Iran-Backed Terrorist Militias in Iraq

    State Press Release: Sanctioning Iran-Aligned Actors Undermining Iraq’s Sovereignty and Exploiting Its Resources

    State Press Release: U.S. Sanctions Target Cuba’s Military Regime, Elites

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594

    AL SHUWAILI, Mohammed Issa Kadhim (Arabic: محمد عيسى كاظم الشويلي)

    • AKA: “ABU MARYAM”
    • Address: Iraq
    • DOB: 19 May 1982
    • Nationality: Iraq
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: B23828763 (Iraq) expires 08 Feb 2033
    • alt. Passport: A12147355 (Iraq) expires 19 May 2025
    • Party Type: Individual
    • Linked to: QASIR, Ali

    Supplemental Information: Al-Shuwaili, operating under the alias Abu Maryam, is a senior official of Kata’ib Sayyid Al-Shuhada (KSS), an Iran-aligned terrorist militia. Since at least 2025, he has collaborated directly with Hizballah illicit finance team members, including Ali Qasir, on the purchase and delivery of weapons into Iraq. He also arranged the payment of millions of dollars to Hizballah to facilitate the purchase of weapons and coordinated logistics related to the transfer and delivery of weapons with Hizballah associates. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Ali Qasir.

    AL-BEHADILI, Mustafa Hashim Lazim (Arabic: مصطفى هاشم لازم البهادلي)

    • AKA:
      • AL BHADLI, Moustafa Hachem Lazem
      • AL-BAHADLI, Mustafa Hashim Lazem
      • LAZIM, Mustafa Hashem
      • LAZM, Mustafa Hashim
      • “AWN, Sayyid”
    • Address: Iraq
    • DOB: 21 Aug 1980
    • Nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: B27823144 (Iraq) expires 15 Apr 2033
    • alt. Passport: A14930721 (Iraq) expires 22 Jan 2027
    • Party Type: Individual
    • Linked to: ASA’IB AHL AL-HAQ

    Supplemental Information: Al-Behadili, also known as Sayyid Awn, is a leader and economic official for Asa’ib Ahl Al-Haq (AAH). Following the U.S. withdrawal from Iraq in 2011, he played an important role in developing an oil trucking and security unit, enabling AAH to become a dominant actor in the Iraqi metals industry and enter the fuel oil sector. Working directly with U.S.-designated AAH senior leader Laith Al-Khazali, he controlled oil smuggling financing and oversaw mineral industry activities. In southern Iraq, he managed oil smuggling operations and AAH projects, using businesses, projects, and government contracts as a front for AAH financial activity. He was also complicit in dealing directly with Iran and the IRGC-Qods Force, negotiating contracts to ship oil from Iran and coordinating with the IRGC-QF on shipping AAH’s oil. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided support for Asa’ib Ahl Al-Haq.

    MAKSUS, Ahmed Khudair Maksus

    • AKA: AL-MAKSUSI, Ahmad Khudayr Maksus
    • Address: Iraq
    • DOB: 06 Oct 1970
    • Nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A5885993 (Iraq) expires 02 Jul 2019
    • Party Type: Individual
    • Linked to: KATA’IB SAYYID AL-SHUHADA

    Supplemental Information: Ahmed Khudair Maksus Maksus is the former Deputy Secretary General of Kata’ib Sayyid Al-Shuhada (KSS) under U.S.-designated Secretary General Hashim Finyan Rahim al-Saraji. KSS is an Iran-aligned terrorist militia that has planned and executed numerous attacks against U.S. personnel in Iraq and Syria. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Kata’ib Sayyid al-Shuhada.

    OFAC Program: [IRAN-EO13902] Executive Order 13902

    AL-BAHADLY, Ali Maarij (Arabic: علي معارج البهادلي)

    • AKA: AL BEHEDILI, Ali Maarij Sewadig
    • Address: Baghdad, Iraq; Alamara, Iraq
    • DOB: 01 Jul 1966
    • POB: Maysan, Iraq
    • Nationality: Iraq
    • Gender: Male
    • Passport: D1019788 (Iraq) expires 30 Jun 2026
    • National ID No.: 0041626 (Iraq)
    • Party Type: Individual
    • Linked to: SAID, Salim Ahmed

    Supplemental Information: Ali Maarij Al-Bahadly is Iraq’s Deputy Minister of Oil, who has abused his position to facilitate the diversion of Iraqi oil products to benefit known Iran-affiliated oil smuggler Salim Ahmed Said as well as Iran-backed terrorist militia Asa’ib Ahl Al-Haq (AAH). Since 2018, Maarij has held multiple positions in Iraq’s Ministry of Oil, including head of the licensing and contracts office, Deputy Minister, and acting Minister of Oil. In his official capacities, he enabled Said to illicitly procure oil products by granting exportation rights to Said’s companies. He authorized trucking several million dollars’ worth of oil per day from the Qayarah oil field to VS Oil in Khor Zubayr for export, where Iranian oil was mixed with Iraqi oil before being shipped to market. He is also responsible for falsifying documentation on the provenance of oil. He is designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided support for Salim Ahmed Said.

    OFAC Program: [CUBA-EO] Executive Order 14404

    LASTRES MORERA, Ania Guillermina

    • Address: Marianao, Havana, Cuba
    • DOB: 19 Aug 1962
    • POB: Marianao, Cuba
    • Nationality: Cuba
    • Gender: Female
    • Party Type: Individual

    Supplemental Information: Lastres is the Executive President of Grupo de Administración Empresarial S.A. (GAESA), the Cuban military-controlled umbrella enterprise that controls an estimated 40 percent or more of the island’s economy. She is responsible for the management of GAESA’s illicit assets held internationally. She is designated pursuant to section 2(a)(i)(E) of E.O. 14404 for being or having been a leader, official, senior executive officer, or member of the board of directors of GAESA.

    The following entities have been added to OFAC’s SDN List:

    OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594

    GULF ENERGY FOR GENERAL TRANSPORT AND MARINE SERVICES AND REAL ESTATE CONSULTANCY LLC (Arabic: طاقة الخليج للنقل العام والخدمات البحرية والاستشارات العقارية محدودة المسؤولية)

    • AKA:
      • GULF ENERGY COMPANY FOR GENERAL TRANSPORT, MARINE SERVICES & REAL ESTATE INVESTMENTS LTD
      • GULF ENERGY FOR GENERAL TRANSPORT, MARINE SERVICES AND REAL ESTATE INVESTMENTS COMPANY LTD
    • Address: Apartment 3, Building 2/56, Zukak 2, Baghdad, Baghdad Governate, Iraq; Berth 12, Khor Al Zubair Port, Al Basrah, Iraq
    • Website: gulfenergy.info
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 12 Apr 2010
    • Organization Type: Sea and coastal freight water transport
    • alt. Organization Type: Transportation and storage
    • Company Number: 38676649 (Iraq)
    • Linked to: AL-BEHADILI, Mustafa Hashim Lazim

    Supplemental Information: One of four Iraqi companies owned or controlled by Mustafa Hashim Lazim Al-Behadili that operate in the oil sector. Designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mustafa Hashim Lazim Al-Behadili.

    GULF ENERGY OIL SERVICES LIMITED (Arabic: طاقة الخليج للخدمات النفطية المحدودة)

    • Address: Baghdad, Iraq
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 13 Oct 2009
    • Organization Type: Support activities for petroleum and natural gas extraction
    • Business Registration Number: 73792 (Iraq)
    • Linked to: AL-BEHADILI, Mustafa Hashim Lazim

    Supplemental Information: One of four Iraqi companies owned or controlled by Mustafa Hashim Lazim Al-Behadili that operate in the oil sector. Designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mustafa Hashim Lazim Al-Behadili.

    GULF GENERAL CONTRACTING LIMITED

    • Address: Baghdad, Iraq
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 05 Feb 2000
    • Business Registration Number: 7249 (Iraq)
    • Linked to: AL-BEHADILI, Mustafa Hashim Lazim

    Supplemental Information: One of four Iraqi companies owned or controlled by Mustafa Hashim Lazim Al-Behadili that operate in the oil sector. Designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mustafa Hashim Lazim Al-Behadili.

    IRAQ INTERNATIONAL ENERGY FOR THE IMPORT AND SALE FOR PETROLEUM PRODUCTS LIMITED (Arabic: طاقة العراق الدولية لاستيراد وبيع المنتوجات النفطية المحدودة)

    • AKA: IRAQ ENERGY INTERNATIONAL FOR IMPORTING AND SELLING OIL PRODUCTS COMPANY LTD
    • Address: Mahala 211, Dar 22, Zukak 11, Harthiya, Baghdad, Iraq
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 25 Jul 2019
    • Organization Type: Support activities for petroleum and natural gas extraction
    • Business Registration Number: 10365 (Iraq)
    • Linked to: AL-BEHADILI, Mustafa Hashim Lazim

    Supplemental Information: One of four Iraqi companies owned or controlled by Mustafa Hashim Lazim Al-Behadili that operate in the oil sector. Designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mustafa Hashim Lazim Al-Behadili.

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    OFAC Programs:

    • [CUBA] Cuban Assets Control Regulations, 31 C.F.R. part 515
    • [CUBA-EO] Executive Order 14404

    GRUPO DE ADMINISTRACION EMPRESARIAL S.A.

    • AKA:
      • GAESA
      • “GRUPO GAE”
    • Address: Edificio de la Marina, Avenida Del Puerto Y Brapia, Havana, Cuba
    • Organization Established Date: 28 Feb 1999
    • Organization Type: Activities of holding companies
    • Entity Code: 60446 (Cuba)

    Supplemental Information: GAESA is a Cuban military-controlled umbrella enterprise that controls an estimated 40 percent or more of Cuba’s economy. It is involved in various sectors and is designed to generate income for the benefit of the regime’s corrupt elites rather than the Cuban people. Its revenues are estimated at more than three times the state’s budget, and it likely controls up to $20 billion in illicit assets. GAESA was designated by the Secretary of State pursuant to section 2(a)(i)(A) of E.O. 14404 for operating or having operated in the financial services sector of the Cuban economy.

    List of Changes:

    • Entity Code: Added: 60446 (Cuba)
    • Program Tags: Added: [CUBA-EO]

    MOA NICKEL SA

    • Address: Moa, Cuba
    • Organization Established Date: 1994
    • Organization Type: Mining of other non-ferrous metal ores

    Supplemental Information: MOA NICKEL SA is a joint venture between Sherritt International Corporation and the Cuban state-owned La Compania General de Niquel. It has exploited Cuba’s natural resources to benefit the regime at the expense of the Cuban people, profiting from assets originally expropriated by the Cuban regime from U.S. persons and corporations. Designated pursuant to section 2(a)(i)(A) of E.O. 14404 for operating or having operated in the metals and mining sector of the Cuban economy.

    List of Changes:

    • Address: Changed: Cuba to: Moa, Cuba
    • Organization Established Date: Added: 1994
    • Organization Type: Added: Mining of other non-ferrous metal ores
    • Program Tags: Added: [CUBA-EO]

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  • Burning Question: Why that new Cuba E.O. – and why today?

    My prompt to Claude:

    So… attached is the text of a brand-new Executive Order targeting Cuba. What I need is a summary in language for non-expert professionals (especially since there are very few Executive Orders in the Cuba program, and a lot rests of legislation and the CACR), and, in addition, an analysis of what is truly new, and what is basically a retread of existing regulatuon and legislation. Finally, if significant parts of this E.O. are not really new, propose a reasoning for why this was issued – and why today (May 1, 2026). Of course, list your sources and check your work to tell me what is well-supported by those sources and what is not.

    And its response: a summary and its analysis of what is new, what’s being repeated… and maybe why:

    New Cuba Executive Order: Summary and Analysis

    Executive Order: “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy” Signed: May 1, 2026

    Plain-Language Summary

    This Executive Order creates a new, targeted sanctions tool for Cuba that works alongside the existing comprehensive embargo (the Cuban Assets Control Regulations, or CACR). Here’s what it does in practical terms:

    Who can be designated? The Secretary of State or Treasury can now place specific foreign persons on the SDN (Specially Designated Nationals) List for any of the following reasons:

    • Operating in key sectors of the Cuban economy — energy, defense, metals/mining, financial services, security, or any other sector Treasury later identifies
    • Being owned or controlled by, or acting on behalf of, the Cuban government or any person already sanctioned under this order
    • Providing material support (financial, technological, or otherwise) to the Cuban government or anyone already blocked
    • Being a leader, official, senior executive, or board member of the Cuban government or a blocked entity
    • Being a Cuban government subdivision, agency, or instrumentality
    • Being responsible for serious human rights abuses in Cuba
    • Being involved in corruption related to Cuba
    • Being an adult family member of a designated person

    What happens when someone is designated? All their U.S.-located property is frozen. U.S. persons are prohibited from transacting with them. The standard 50% ownership rule applies (any entity 50%+ owned by a blocked person is also blocked).

    Travel ban: Designated persons are barred from entering the United States.

    Secondary sanctions on foreign banks: The Treasury Secretary can sanction any foreign financial institution that facilitates significant transactions for anyone designated under this order. The penalties range from losing access to U.S. correspondent banking accounts to having the institution’s own assets frozen — a powerful tool to pressure non-U.S. banks to cut ties with designated persons.

    Carve-out for existing licenses: Importantly, Section 2(b) specifies that the order does not override any licenses already issued under the CACR (31 CFR Part 515). This means existing general licenses for travel, remittances, telecommunications, and other authorized Cuba transactions remain valid.

    What Is Truly New

    Despite Cuba already having one of the most comprehensive U.S. sanctions programs in existence, this E.O. adds several genuinely novel elements:

    1. A List-Based (Targeted) Sanctions Layer on Top of a Comprehensive Program

    This is the single most significant structural innovation. The CACR operates as a comprehensive embargo: it broadly prohibits nearly all transactions involving Cuba or Cuban nationals, with limited carve-outs via general and specific licenses. It is rooted in the Trading With the Enemy Act (TWEA) of 1917, not IEEPA.

    This new E.O. creates an IEEPA-based, list-driven sanctions program that can target specific individuals and entities — including non-Cuban third-country persons — for designation on the SDN List. Cuba has historically had very few SDN-listed persons compared to programs like Iran, Venezuela, or Russia. This E.O. gives OFAC a mechanism to build a robust Cuba SDN list. [Well-supported: OFAC’s Cuba sanctions page and the CACR structure confirm the absence of a prior IEEPA-based blocking authority for Cuba of this scope.]

    2. Explicit Secondary Sanctions on Foreign Financial Institutions

    Section 4 authorizes the Treasury to penalize foreign banks that facilitate significant transactions with designated persons. This is entirely new for the Cuba program. The CACR has never had a formal secondary sanctions component comparable to what exists in the Iran, Russia, or Venezuela programs. While non-U.S. banks have always had to worry about U.S.-nexus transactions under the CACR, this E.O. gives Treasury a dedicated tool to threaten foreign banks with loss of U.S. correspondent accounts or full asset freezes — even when no U.S. nexus exists in the underlying transaction.[Well-supported: multiple legal analyses confirm the CACR lacked formal secondary sanctions.]

    3. Human Rights and Anti-Corruption Designations

    Sections 2(a)(i)(G) and (H) create specific authority to designate persons responsible for serious human rights abuses or corruption in Cuba. While the U.S. has previously sanctioned Cuban officials under other authorities (e.g., Global Magnitsky, Section 7031(c)), this order creates a Cuba-specific human rights and anti-corruption designation authority. [Well-supported by the E.O. text; partially new since other tools existed but were not Cuba-specific.]

    4. Adult Family Member Provision

    Section 2(a)(i)(I) allows designation of adult family members of sanctioned persons. This is an unusually aggressive provision rarely seen in other sanctions programs. It functions as a deterrent against asset concealment through family members. [Well-supported: this provision is noted as novel by multiple press analyses.]

    5. Sectoral Targeting Authority

    The authority to designate anyone “operating in” named sectors of the Cuban economy — with an open-ended clause allowing Treasury to add more sectors — mirrors the approach used against Iran under E.O. 13902 and Russia under E.O. 14024. This is new for Cuba. [Well-supported: the sectoral structure clearly parallels the Iran/Russia models.]

    What Is Largely a Retread

    1. Broad Property-Blocking Prohibitions

    The property blocking, transaction prohibitions, and anti-evasion provisions in Sections 2(a)-(c) are standard IEEPA boilerplate found in virtually every modern sanctions E.O. (Venezuela, Iran, Russia, Myanmar, etc.). The specific language is nearly identical to E.O. 13850 (Venezuela) and E.O. 14024 (Russia). [Well-supported: direct textual comparison.]

    2. Blocking Government of Cuba Property

    The CACR already comprehensively blocks all property of Cuba and Cuban nationals within U.S. jurisdiction. Adding an IEEPA-based blocking authority for the “Government of Cuba” and its subdivisions (Sections 2(a)(i)(B), (C), (F)) is legally additive but practically redundant for most transactions that were already prohibited. [Well-supported: 31 CFR 515.201 already broadly prohibits dealings in property in which Cuba has an interest.]

    3. Material Support / Ownership Chains

    The authority to designate persons providing material support or owned/controlled by blocked persons (Sections 2(a)(i)(B)-(D)) is standard across IEEPA programs and largely duplicates what the CACR already prohibits in practice, though it adds the ability to formally list and publicize specific designees. [Moderately supported: the CACR’s comprehensive prohibition achieves much of the same result, but the formal listing adds enforcement clarity.]

    4. Immigration Restrictions

    Section 3’s travel ban applies IEEPA-based visa restrictions to designated persons. The U.S. already had authority to bar Cuban officials under other statutes (e.g., INA Section 212(f), Section 7031(c)). The Trump Administration updated NSPM-5 in July 2025 to prohibit entry of ministers, deputy ministers, and members of Cuba’s Council of State. This E.O. broadens the scope but the concept is not new. [Well-supported.]

    5. Definitions and Delegations

    Sections 5-8 are standard boilerplate present in every modern IEEPA sanctions Executive Order.

    Why Was This Issued — and Why Today?

    Given that much of this E.O.’s blocking authority is practically redundant with the existing CACR, the question of why is important. Several factors likely explain the timing and purpose:

    1. The CACR Is Structurally Outdated for Modern Sanctions Strategy

    The CACR derives from the Trading With the Enemy Act — a World War I-era statute — and operates as a blanket prohibition. It lacks the targeted, list-based architecture that OFAC has refined over the past two decades in programs like Iran (E.O. 13846, 13902), Venezuela (E.O. 13850), and Russia (E.O. 14024). Those programs allow OFAC to name-and-shame specific entities, trigger the 50% rule against their subsidiaries, and activate secondary sanctions against third-country facilitators. This E.O. imports that modern toolkit into the Cuba context. [Well-supported analytically, though no official has stated this rationale explicitly.]

    2. Plugging the Secondary Sanctions Gap

    The CACR’s most significant limitation is that it binds only “persons subject to U.S. jurisdiction” — a category broader than “U.S. persons” but still fundamentally different from the extraterritorial reach of IEEPA-based secondary sanctions. As the administration pursues maximum pressure on Cuba, the inability to threaten foreign banks with loss of correspondent accounts was a significant gap. This E.O. closes it. [Well-supported: legal commentators have noted the CACR’s lack of secondary sanctions.]

    3. Building a Cuba SDN List for Maximum Pressure

    Creating an IEEPA-based designation authority lets the administration build a public SDN list of Cuban officials, regime-connected business figures, and third-country facilitators. This is a far more potent communication and deterrence tool than the CACR’s blanket prohibition, which is comprehensive but anonymous. Named designations generate headlines, trigger compliance screening hits, and create personal consequences for individuals. [Well-supported analytically.]

    4. The Supreme Court Setback on Tariffs

    In February 2026, the Supreme Court struck down the IEEPA-based tariffs from E.O. 14380 as exceeding IEEPA’s authority. This E.O. retreats to the well-established territory of IEEPA-based blocking sanctions — a use of IEEPA that courts have consistently upheld — while still escalating pressure. [Well-supported by reporting on the Supreme Court decision.]

    5. May 1 Timing: Maximum Symbolic Impact

    The choice of May 1 — International Workers’ Day — is almost certainly deliberate. May Day is one of the most politically significant dates on the Cuban revolutionary calendar. Cuba holds its largest annual public rally on this day, with mass marches through Havana. In 2026, tens of thousands gathered in Havana’s José Martí Anti-Imperialist Square, with Raúl Castro and Miguel Díaz-Canel in attendance, under banners reading “Down with Imperialism.” Signing a new sanctions escalation on this date sends a pointed message to the regime during its most visible moment of public political theater. [Well-supported: multiple news outlets confirm the May Day rally and the simultaneous E.O. announcement.]

    6. Domestic Political Signaling

    Cuban-American Republican legislators — including Carlos Giménez, María Elvira Salazar, and Mario Díaz-Balart — had publicly called for exactly this type of asset-freezing authority. Giménez immediately endorsed the order on social media. The E.O. delivers on commitments made to a politically important constituency. [Well-supported by reporting.]

    Source Assessment

    SourceConfidence
    Text of the E.O. itself (uploaded PDF)Primary source — highest confidence
    OFAC Cuba Sanctions page (ofac.treasury.gov)Official — high confidence
    CACR (31 CFR Part 515) via eCFROfficial — high confidence
    White House Fact Sheet (whitehouse.gov, May 1, 2026)Official — high confidence
    Baker McKenzie analysis of E.O. 14380 (Feb 2026)Reputable law firm — high confidence
    Wikipedia “2026 Cuban crisis” articleSecondary compilation — moderate confidence; used for timeline/context only
    CubaHeadlines reporting (multiple articles, May 1, 2026)News aggregator — moderate confidence; used for reaction/context
    Al Jazeera / Washington Post reporting on May Day rallyMajor outlets — high confidence for factual reporting on the rally
    Skuld maritime advisory on Cuba sanctionsIndustry advisory — moderate-high confidence for CACR structure
    TURBOFAC commentary on CACR provisionsSpecialized sanctions research tool — high confidence for legal analysis
    My own comparative analysis of E.O. structures (Venezuela, Iran, Russia)Analytical inference — moderate confidence; based on pattern recognition across programs rather than official statement of intent

    Key caveat: My reasoning about why this E.O. was issued on this date is analytical inference based on circumstantial evidence. No official has publicly stated “we chose May 1 to counter Cuba’s May Day rally” or “we needed to replace the tariff authority struck down by the Supreme Court.” These are well-grounded hypotheses, not confirmed facts.

    Some of this I get – I thought E.O. 14024 (the Russian Harmful Foreign Activities one) rehashed a bunch of stuff that was already out there. And I think the tariff angle is a good pickup… although I’m not sure it’s directly tied to the Supreme Court decision.

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  • For May Day (cue the irony): a new Cuba-related Executive Order!

    The as-yet unnumbered E.O. (Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy):

    20260501_eoDownload

    Yes, I will sic Claude on this – I do notice he invokes IEEPA (International Emergency Economic Powers Act) instead of TWEA (Trading with the Enemy), which is where the overwhelming bulk of restrictions and prohibitions derive from. I also notice there are secondary sanctions…

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  • Burning Question: Why can’t Cuba sanctions be lifted by the President (like the North Korea ones)?

    In 2008, President Bush performed a legal maneuver that essentially updated the “operating system” for North Korea sanctions from an old version (TWEA) to a modern version (IEEPA). While this was technically possible for North Korea, it is legally impossible for a President to do the same for Cuba without Congress.

    The reason lies in the difference between Executive Orders (rules the President makes) and Statutory Law (rules Congress makes).

    The Layperson Explanation: “The Golden Handcuffs”

    Imagine sanctions are a fence built around a country.

    • North Korea’s Fence (Pre-2008): The fence was built by President Truman in 1950 using his own authority. Because a President built it, a later President (Bush) had the power to tear it down or rebuild it using different materials (swapping TWEA for IEEPA) without asking permission.
    • Cuba’s Fence: This fence was also originally built by a President (Kennedy). However, in 1996, Congress passed a law (the Helms-Burton Act) that effectively poured concrete over the fence posts. Congress declared that the President’s fence was now Federal Law.
    • The Result: The President can no longer simply swap the legal authority or take down the fence. Congress holds the only key to unlock it. If the President tried to “terminate” the TWEA authority for Cuba, they would be violating the law passed in 1996 which mandates those specific restrictions remain in place until Cuba becomes a democracy.

    Comparison: Creation and Evolution of Sanctions

    The two programs started similarly but diverged wildly in the 1990s.

    1. North Korea: The “Executive” Model

    • Origin (1950): Upon the outbreak of the Korean War, President Truman declared a national emergency and imposed sanctions using the Trading with the Enemy Act (TWEA).
    • The “Grandfather” Clause (1977): In 1977, Congress passed a law (IEEPA) saying TWEA could only be used for wars, not peacetime emergencies. However, they allowed existing emergencies (like North Korea and Cuba) to continue under TWEA (“grandfathered in”).
    • The 2008 Swap: To aid nuclear negotiations, President Bush wanted to remove North Korea from the list of TWEA countries. Because these sanctions were largely kept in place by Executive Order, he issued Proclamation 8271, terminating the TWEA emergency. He immediately issued Executive Order 13466 to place North Korea under IEEPA authorities instead. This kept sanctions in place but updated their legal basis to the modern standard.

    2. Cuba: The “Statutory” Model

    • Origin (1960s): President Kennedy imposed the embargo under the Foreign Assistance Act and TWEA. For decades, it operated just like the North Korea program—renewed annually by the President.
    • The Codification (1996): In reaction to Cuba shooting down two American civilian planes (Brothers to the Rescue), Congress passed the Helms-Burton Act (LIBERTAD Act).
      • Section 102(h): This specific section “codified” the embargo. It stated that all regulations in effect on March 1, 1996, were now law.
    • The Lock: This removed the President’s discretion. While Presidents (like Obama or Biden) can modify the rules (licensing travel or remittances), they cannot terminate the underlying authority (TWEA) or the embargo itself. The law requires a Presidential certification to Congress that a “transition government” is in power in Cuba before the sanctions can be lifted.

    Summary of Differences

    FeatureNorth Korea Sanctions (2008 Era)Cuba Sanctions (Present Day)
    Primary AuthorityIEEPA (Executive discretion)TWEA (Congressionally Mandated)
    Can the President End it?Yes. (Until 2016*)No. Requires Congress.
    Legal BasisExecutive Orders & Proclamations.Helms-Burton Act (1996) (Statutory Law).
    Renewal ProcessPresident declares yearly “Emergency”.President must renew TWEA authority annually or violate the statute.

    *Note: Since 2016, Congress has passed stricter laws on North Korea (NKSPEA), effectively beginning to “codify” those sanctions as well, making them harder to lift today than they were in 2008.

    Sources

    • Bush’s 2008 Action: Proclamation 8271 (Termination of the Exercise of Authorities Under the Trading With the Enemy Act With Respect to North Korea) and Executive Order 13466.
    • Cuba Codification: The Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996 (Pub. L. 104-114), specifically Title I, Section 102(h).
    • TWEA vs. IEEPA History: Congressional Research Service Report R45618, “The International Emergency Economic Powers Act: Origins, Evolution, and Use.”
    • General Comparison: Haney, P. J., & Vanderbush, W. (1999). “The Role of Ethnic Interest Groups in U.S. Foreign Policy: The Case of the Cuban American National Foundation.” International Studies Quarterly.

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