Cuba Sanctions and Business Advisory

Indirect transactions with Cuba Restricted List entities

U.S. persons were already barred from direct financial transactions with entities on the State Department’s Cuba Restricted List. They are now also barred from indirect ones: taking part in a transfer of funds where the sender or final recipient is a listed entity. The rule makes exceptions for travel-related transactions begun, and commercial engagements in place, before the entity was added to the list. Many general licenses were amended to exclude these transactions. (31 C.F.R. § 515.209; FAQ 1271)

U-turn transfers

The general license that let U.S. banks process certain funds transfers in which Cuba or a Cuban national has an interest, starting and ending outside the United States, was removed. U.S. banks are now authorized only to reject them. (31 C.F.R. § 515.584(d); FAQ 1272)

Accounts for Cuban entrepreneurs

U.S. banks may no longer open or keep accounts for Cuban independent private sector entrepreneurs under the former authorization. Existing accounts must be blocked, and a specific OFAC license is needed to unblock them. (31 C.F.R. § 515.584(h); FAQ 1273)

Professional meetings

The general license to attend or organize professional meetings or conferences in Cuba was removed. People in Cuba on September 30 under that authorization may complete authorized transactions through October 30, 2026, if they leave by then, and trips may be cancelled and refunded through the same date. Professional research remains generally licensed under its existing conditions. (31 C.F.R. § 515.564; FAQ 1275)

Educational travel

Group people-to-people travel is no longer authorized, and other educational travel is narrowed. Travelers who completed at least one travel-related transaction, such as buying a flight or reserving lodging, before September 30, 2026 may still travel under the prior rules. (31 C.F.R. § 515.565; FAQ 1274)

New Cuba Sanctions Regulations

OFAC issued 31 C.F.R. part 516 to implement Executive Order 14404 of May 1, 2026. OFAC published these regulations in abbreviated form and says it intends to issue a more comprehensive set.

U.S. companies and individuals

Whether a planned activity falls within a general license, needs a specific license, or is prohibited. Preparation of OFAC specific license applications. Screening of Cuban counterparties against the Cuba Restricted List and the SDN List.

Non-U.S. companies

Review of exposure under Executive Order 14404 before entering a Cuba-related deal, and identification of where U.S. persons, U.S. banks, or U.S. dollar payments touch the transaction.

Cuban nationals

Advice on the requirements of U.S. law, which the regulations generally authorize U.S. lawyers to provide (31 C.F.R. § 515.512). Cuban nationals who have taken up residence in the United States, or permanent residence outside Cuba, may qualify as “unblocked nationals” (31 C.F.R. § 515.505), which changes what U.S. persons may do with them.

Trademarks

Protection of your brand in Cuba. See Cuba Trademark Protection.

What we do and do not do

We advise on U.S. law. We do not advise on Cuban law, and we do not assist any person in avoiding U.S. sanctions.