As of June 4, 2026, GAESA, MININT, and MINFAR are all blocked pursuant to Executive Order (E.O.) 14404. These three entities are also blocked pursuant to the Cuban Assets Control Regulations (CACR), and MININT is also blocked pursuant to the Global Magnitsky sanctions program under E.O. 13818, as of January 2021. Non-U.S. persons, including foreign financial institutions, are exposed to sanctions risk for engaging in transactions with persons designated under E.O. 14404. Sanctions risk also extends to transactions with any entity in which GAESA, MININT, or MINFAR own, directly or indirectly, a 50 percent or greater interest. Many of the entities listed on the CRL are 50 percent or more owned by one of these three entities and therefore present the same sanctions risk. In addition, any non-blocked CRL entity may become the subject of future sanctions actions. Consequently, persons transacting with any entity on the CRL may run the risk of themselves being sanctioned by the U.S. government.

Non-U.S. persons should consider conducting enhanced due diligence to inform a risk-based approach to transactions with GAESA, MININT, MINFAR, or any entity in which they own, directly or indirectly, a 50 percent or greater interest. As part of such due diligence, non-U.S. persons are encouraged to consult all available sources to inform their independent assessment regarding the network of entities under GAESA, MININT, and MINFAR, including trusted sources provided by the U.S. government, such as the CRL.