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pc nid 95451 Sep 29, 2026 pdonofrio@vixio.com US Track 2 Ministry of Finance horizon scanning
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United States Treasury Office of Foreign Assets Control Publishes Cuba Sanctions Regulations

On September 30, 2026, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC) published the Cuba Sanctions Regulations, 31 Code of Federal Regulations (CFR) Part 516, to implement Executive Order 14404 issued on May 1, 2026. The executive order, titled "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," was issued pursuant to the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act (NEA). The regulations establish comprehensive prohibitions on transactions involving designated persons and entities related to Cuba. Key provisions include blocking of property and interests in property of sanctioned individuals and entities; prohibitions on transactions by U.S. persons and within the United States involving blocked property; and restrictions on foreign financial institutions conducting transactions for sanctioned parties. The regulations define sanctionable conduct to include persons operating in Cuba's energy, defense, metals and mining, financial services, and security sectors, as well as those responsible for human rights abuses or corruption. The regulations also impose travel restrictions on designated aliens and authorize OFAC to impose sanctions on foreign financial institutions, including prohibitions on correspondent accounts and payable-through accounts in the United States. OFAC intends to supplement these regulations with a more comprehensive set of provisions, including additional interpretive guidance, definitions, general licenses, and other regulatory provisions. The agency has published five new Cuba-related Frequently Asked Questions and amended 29 existing ones. U.S. persons and financial institutions must ensure compliance with these prohibitions. Willful violations may be subject to criminal penalties under 50 U.S.C. 1705, which requires a mens rea element of willfulness. Further guidance and licensing procedures are available through OFAC's website at https://ofac.treasury.gov.

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US Office of Foreign Assets Control Publishes Cuba Sanctions Regulations

On September 30, 2026, the US Office of Foreign Assets Control (OFAC) published its new Cuba Sanctions Regulations (31 Code of Federal Regulations (CFR) Part 516) to implement Executive Order 14404 . The regulations establish comprehensive prohibitions on transactions involving designated individuals and entities related to Cuba. Key provisions of the regulations include blocking of property and interests in property of sanctioned individuals and entities; prohibiting transactions by US individuals and entities involving blocked property; and restricting foreign financial institutions conducting transactions for sanctioned parties. The regulations define sanctionable conduct to include individuals and entities operating in Cuba's energy, defense, metals and mining, financial services and security sectors, as well as those responsible for human rights abuses or corruption. The regulations also impose travel restrictions on designated individuals and authorize OFAC to impose sanctions on foreign financial institutions, including prohibitions on correspondent accounts and payable-through accounts in the US. The regulations are currently available for public inspection and will take effect upon publication in the Federal Register on September 30, 2026 . Additionally, OFAC amended its Cuban Assets Control Regulations (31 CFR Part 515) to implement portions of President Trump's foreign policy toward Cuba, including including as directed by National Security Presidential Memorandum 5 (NSPM-5). OFAC also published five new Cuba-related frequently asked question (FAQ) documents, as well as amending 29 existing FAQ documents, to supplement its new Cuba sanctions program. Concurrently, OFAC published an alert which highlights increased sanctions risks for transactions involving Cuba.