No. All existing prohibitions and authorizations pursuant to the CACR remain in effect. E.O. 14404 was issued pursuant to the International Emergency Economic Powers Act ( IEEPA ), and is distinct from the CACR, which is issued pursuant to the Trading with the Enemy Act ( TWEA ), among other… Read more
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… Read more
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… Read more
As a general matter, U.S. sanctions under E.O. 14404 are not focused on disrupting the delivery of food, medicine, or medical devices to Cuba. The U.S. government does not intend to target non-U.S. persons under E.O. 14404 for engaging in transactions related to the provision, directly or… Read more
The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater… Read more
Travel-related transactions are permitted by general or specific licenses for certain travel related to the 12 categories of activities identified in 31 CFR § 515.560(a) . Those travel-related transactions permitted by general license, subject to specified criteria and conditions, include: family… Read more
On September 30, 2026, OFAC amended 31 CFR § 515.565(a) to restore particular requirements for authorized educational activities related to Cuba. As of September 30, 2026, the requirements related to a person's use of the educational activities- authorization depend on whether the person engaging… Read more
31 CFR § 515.564 (a)(1) contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional research in Cuba. Among other things, this general license authorizes, subject to conditions, professional… Read more
No, persons subject to U.S. jurisdiction may not travel to Cuba to engage in "people-to-people" educational exchanges on an individual basis or, effective September 30, 2026, as part of a group. However, § 515.565(c) includes a grandfathering provision, authorizing certain educational travel that… Read more
Yes, under certain circumstances. Persons subject to U.S. jurisdiction may engage in transactions in U.S. dollars in Cuba or with Cuban nationals with respect to activity that is authorized pursuant to the Cuban Assets Control Regulations (CACR) . For example, payments for telecommunications… Read more