No. E.O. 14404 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, or the Secretary of State, in consultation with the Secretary of the Treasury, to impose blocking sanctions on any foreign person determined to operate or have operated in the following sectors of the Cuban economy: (1) energy; (2) defense and related materiel; (3) metals and mining; (4) financial services; and (5) security. E.O. 14404 also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to determine that the prohibitions in section 2(a)(i)(A) of E.O. 14404 apply to additional sectors of the Cuban economy.
The identification of these sectors exposes foreign persons that operate or have operated in such sectors to sanctions risk; however, it does not automatically impose sanctions on all persons who operate or have operated in those sectors. Only foreign persons determined pursuant to E.O. 14404 to operate or have operated in an identified sector are subject to sanctions under this criterion.
Persons should also note that E.O. 14404 is separate from the Cuban Assets Control Regulations (CACR), 31 CFR part 515. A person that is not sanctioned pursuant to E.O. 14404 may still be subject to CACR prohibitions or restrictions. For further information regarding the CACR prohibitions, please see FAQs 1252, 1254, and 1255.