The U.S. government does not intend to target non-U.S. persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, through August 12, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, or transfer such assets to another jurisdiction could expose non-U.S. persons to significant sanctions risk.
Non-U.S. persons unable to wind down transactions involving GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, before August 12, 2026, are encouraged to contact the OFAC Compliance Hotline.
Persons subject to U.S. jurisdiction, including U.S. entities owned or controlled by U.S. persons, have long been prohibited pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, from transacting with GECOMEX and GEMAR, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving GECOMEX or GEMAR, including in connection with a non-U.S. person's wind down of activities with GECOMEX or GEMAR, unless separately authorized by OFAC. Relevant authorizations may include humanitarian-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1. For additional information on GL 1, see FAQ 1253.