Trade restrictions on Cuba were first introduced by the US in 1960 following the communist revolution. It continues to operate a combination of Specially Designated Nationals and trade restrictions targeting the government. Having been significantly relaxed under President Obama (2009-17), President Trump (2017-2021) oversaw a renewed tightening of measures, which has continued under current President Biden.
A second Cuba-related sanctions regime was established in May 2026, expanding existing Cuba sanctions to target repression, national security threats, serious human rights abuses, corruption, material support to the Cuban government, and activity in key Cuban sectors.
Sanction Name
Implementation Of The Cuban Democracy Act
First Imposed
Last updated
Targets
Specially Designated National:
• Members of the Cuban government.
• Some entities under the control of, or which act on behalf of, the Cuban Military, intelligence and security services.
Trade Restriction and Travel Ban:
• Prohibits direct financial transactions between US citizens and Cuban nationals. This includes so-called “U-Turn transactions”, relating to transactions originating and terminating outside the US, which have been prohibited since September 2019.
• Prohibits travel to Cuba by US citizens.
Exemptions
1. Certain transactions related to Cuban pharmaceuticals, medical research and humanitarian-related services are authorised.
2. Travel to Cuba by US citizens is allowed for a small number of defined purposes.
3. Remittances to Cuban citizens of up to $1,000 per quarter are allowed, although remittances to Cuban officials or Cuban Communist Party members are prohibited. Entities identified as being controlled by the Cuban military are banned from receiving remittances.
On 7th May 2026, the US announced its first designations under Executive Order 14404, targeting Grupo de Administración Empresarial S.A. (GAESA), the Cuban military-controlled conglomerate, GAESA Executive President Ania Guillermina Lastres Morera, and Moa Nickel S.A. (MNSA), a nickel and cobalt joint venture operating in Cuba’s metals and mining sector.
On 18th May 2026, the US announced a second round of designations, targeting nine Cuban government officials and the Directorate of Intelligence, while redesignating Cuba’s Ministry of the Interior (MININT), the Policía Nacional Revolucionaria (PNR), and senior PNR officials previously sanctioned under the Global Magnitsky programme. Designated individuals included Eddy Manuel Sierra Arias, head of the PNR, Rosabel Gamon Verde, Minister of Justice, Vicente de la O Levy, Minister of Energy and Mines, and Oscar Alejandro Callejas Valcarce, Chief of the Political Directorate within the Interior Ministry.
Sanction Name
Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated Nationals:
• Members of the Cuban government responsible for repression, serious human rights abuses, corruption, or actions threatening US national security and foreign policy.
• Cuban military, intelligence, security, and law enforcement officials and entities.
• Persons providing material support to the Cuban government or to designated persons.
• Entities operating in designated sectors of the Cuban economy, including the energy, defence and related materiel, financial services, security, and metals and mining sectors.
• Initial designations included Grupo de Administración Empresarial S.A. (GAESA), Ania Guillermina Lastres Morera, and Moa Nickel S.A.; subsequent designations included the Ministry of the Interior (MININT), the Policía Nacional Revolucionaria, the Directorate of Intelligence, and senior Cuban government officials.
Asset Freeze and Transaction Restrictions:
• All property and interests in property of designated persons within US jurisdiction are blocked.
• US persons are prohibited from engaging in transactions with designated persons unless authorised by OFAC.
• Entities owned 50% or more, directly or indirectly, by designated persons are also subject to blocking restrictions.
Secondary Sanctions:
• Foreign financial institutions may be subject to sanctions if they knowingly conduct or facilitate significant transactions for designated persons.
• Non-US persons may face sanctions exposure for providing material support to designated persons or engaging in certain transactions involving targeted sectors of the Cuban economy.
Travel Restrictions:
• Designated individuals may be subject to visa restrictions and inadmissibility to the US.
Exemptions
1. Certain transactions authorised by OFAC through general or specific licences, including transactions necessary for the wind-down of dealings involving designated persons during authorised wind-down periods.
2. Activities conducted by the US Government, the United Nations, and certain international organisations are exempt from the sanctions prohibitions.
3. Humanitarian activities, including the provision of food, agricultural commodities, medicine, medical devices, and certain humanitarian assistance, may be authorised under existing OFAC licensing frameworks.
4. Transactions that fall within existing authorisations under the Cuban Assets Control Regulations (CACR), including certain family remittances, telecommunications services, and informational materials, may remain permissible provided they do not involve blocked persons or otherwise violate the terms of the applicable licence.
5. Certain legal services, compliance activities, and payments of professional fees related to authorised activities may be permitted under OFAC general licences or specific licences.
