On May 1, 2026, President Donald Trump issued an Executive Order (EO) titled, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.” Pursuant to the EO, the Secretary of State and/or Secretary of Treasury are able to designate for blocking sanctions any foreign person determined by either of them to:
- operate in or have operated in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, or any other sector of the Cuban economy;
- be owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba or any person whose property or interests in property are blocked under this EO;
- own or control, directly or indirectly, any person whose property or interests in property are blocked under this EO;
- have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba or any person whose property or interests in property are blocked under this EO;
- be or have 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 under this EO;
- be a political subdivision, agency, or instrumentality of the Government of Cuba;
- be responsible for or complicit in, or to have directly or indirectly engaged in or attempted to engage in, serious human rights abuse in Cuba;
- be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, corruption related to Cuba, including corruption by, on behalf of, or otherwise related to the Government of Cuba, or a current or former official at any level of the Government of Cuba, such as the misappropriation of public assets, expropriation of private assets for personal gain or political purposes, or bribery; or
- be an adult family member of a person designated under this EO.
The EO details certain exceptions and clarifications to the above prohibitions. It also restricts immigration and nonimmigration entry into the United States of certain Cuban persons.
The EO also imposes sanctions on foreign financial institutions (FFI) that conduct or facilitate any significant transaction for or on behalf of any person whose property or interests in property are blocked under this EO pursuant to this order. These “secondary sanctions” on FFIs are intended to discourage non-U.S. banks – typically outside of the direct jurisdiction of the United States – from engaging in activities that undermine U.S. sanctions policy. Essentially, under such sanctions, if a FFI conducts business with an entity or person designated by the State or Treasury Departments pursuant to this EO, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) would have the power to designate the FFI, and place it on the Specially Designated Nationals (SND) List itself.