On December 21, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three entities it has identified are controlled by the Cuban military and that have “strategic roles in the Cuban economy.” OFAC has placed the following three entities on the Specially Designated Nationals (SDN) List: (1) Grupo de Administración Empresarial S.A. (GAESA) and two of its subsidiaries, (2) Financiera Cimex S.A. (FINCIMEX) and (3) Kave Coffee, S.A. According to OFAC, GAESA is a Cuban military-controlled umbrella enterprise with interests in the tourism, financial investment, import/export, and remittance sectors of Cuba’s economy. GAESA’s portfolio includes businesses incorporated in Panama to bypass CACR-related restrictions. Although Cuba is an embargoed country under U.S. sanctions, the listing of these companies also targets their operations in Panama and clearly states the U.S. government’s position that these companies are ultimately Cuban state-owned businesses under which no license exceptions would generally apply.

GAESA and FINCIMEX are also listed on the State Department’s List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List). This list identifies entities and subentities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. Although the SDN listing is more broadly restrictive, being placed on the State Department’s Cuba Restricted List means that direct financial transactions with such listed entities are restricted and certain license exceptions do not apply.