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Cuba · English & Español

Cuba: protect the brand, and know the rules first.

On September 30, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) tightened the rules on transactions involving Cuba. Some paths narrowed or closed. One that matters to brand owners did not change: the authorization that allows trademark filings in Cuba. We help companies in the United States, Latin America and Europe protect their brands in Cuba and review Cuba-related plans under current U.S. sanctions law, in English or Spanish.

September 30, 2026

What changed on September 30, 2026

OFAC amended the Cuban Assets Control Regulations and issued new Cuba Sanctions Regulations, both effective September 30, 2026. Among the changes:

  • U.S. persons may no longer take part in indirect financial transactions with entities on the State Department’s Cuba Restricted List, in addition to direct ones.
  • The general license for “U-turn” funds transfers was removed.
  • U.S. banks may no longer hold accounts for Cuban independent private sector entrepreneurs.
  • The general authorizations for professional meetings and for group people-to-people travel in Cuba were removed.
  • New regulations at 31 CFR part 516 implement Executive Order 14404, which allows sanctions on non-U.S. persons in certain sectors of the Cuban economy.
Read the full summary and sources →
Clients

Who we work with

  • Cigar and tobacco manufacturers in the Dominican Republic, Nicaragua, Honduras and Europe weighing a presence in Cuba
  • U.S. companies and individuals with Cuba-related plans, customers or suppliers
  • Cuban nationals, in Cuba or abroad, who need advice on the requirements of U.S. law
  • Brand owners whose names have a history in Cuba
Contact

Talk with counsel before you act.

Tell us briefly what you are considering. We respond to every inquiry, in English or Spanish.

General information only

This page is general information, not legal advice. It summarizes OFAC’s published rules as of September 30, 2026. Sanctions rules change, sometimes without advance notice, and the facts of each situation matter. No attorney-client relationship forms until you and the firm sign an engagement letter. Please do not send confidential information before then.

Rules as published September 30, 2026. Page reviewed October 1, 2026.