Frequently Asked Questions

1179. What type of small businesses are considered an “independent private sector entrepreneur” (as defined in 31 CFR § 515.340)?

Section 515.340 defines the term “independent private sector entrepreneur” to mean a Cuban national who is not a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party, and who is one or more of the following: (a) an owner, including a self-employed… Read more

1251. What does Executive Order (E.O.) 14404 of May 1, 2026, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy," do?

E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, "Addressing Threats to the United States by the Government of Cuba." E.O. 14404 authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on… Read more

1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA?

Generally, yes, but 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 GAESA, or any entity in which GAESA owns, directly or indirectly, a 50… Read more

1253. What does Cuba-related General License (GL) 1, "Transactions Authorized Pursuant to the Cuban Assets Control Regulations," authorize?

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… Read more

1256. Are all persons that operate or have operated in the five sectors of the Cuban economy identified in E.O. 14404 sanctioned by OFAC under E.O. 14404?

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… Read more

1255. Are persons blocked pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, automatically blocked pursuant to the E.O. 14404?

No. Persons blocked or otherwise identified pursuant to the CACR are not automatically blocked pursuant to the E.O. 14404 . The CACR and E.O. 14404 are separate sanctions authorities. E.O. 14404 separately authorizes the imposition of blocking sanctions and certain less-than-blocking sanctions… Read more

1252. Does E.O. 14404 alter U.S. sanctions on Cuba pursuant to the Cuban Assets Control Regulations (CACR)?

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

1258. I am a non-U.S. person, what is my exposure to sanctions risk for transacting with entities owned by Grupo de Administración Empresarial S.A. (GAESA), the Cuban Ministry of the Interior (MININT), or the Cuban Ministry of the Revolutionary Armed Forces (MINFAR), including their subsidiaries listed on the Cuba Restricted List (CRL)?

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence