On May 7, 2026, OFAC issued Cuba-related GL 1, authorizing all transactions prohibited by E.O. 14404 where such transactions are authorized or exempt under the Cuban Assets Control Regulations, 31 CFR part 515 (CACR).
GL 1 includes transactions authorized by either general or specific license issued pursuant to the CACR. GL 1 is intended to ensure activity authorized or exempt under the CACR is not interrupted if a foreign person already blocked or otherwise identified under the CACR is also blocked pursuant to E.O. 14404, such as Grupo de Administración Empresarial S.A. (GAESA). In such cases, no additional OFAC authorization beyond GL 1 would be required to engage in CACR-authorized activities.
GL 1 does not expand the scope of any authorization or exemption under the CACR. Any transaction must continue to comply with all relevant conditions and limitations as provided in the CACR to be authorized under GL 1. As with all OFAC GLs, GL 1 is "self-executing," meaning that persons who assess that their transactions fall within the scope of the authorization may proceed without further assurance from OFAC. Transactions prohibited by E.O. 14404 require additional OFAC authorization if not authorized or exempt under the CACR.