1276. On October 15, 2026, the Department of State designated the Banco Internacional de Comercio, S.A. (BICSA) pursuant to Executive Order (E.O.) 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with BICSA?

Answer

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 divestment from or the wind down of transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, through November 14, 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 a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.

Foreign persons unable to divest from or wind down transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly, a 50 percent or greater interest, before November 14, 2026, are encouraged to contact the OFAC Compliance Hotline.

Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with BICSA, a Cuban State-Owned entity, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving BICSA, including in connection with a non-U.S. person's wind down of activities with BICSA, unless separately authorized by OFAC. Relevant authorizations may include humanitarian and diplomatic-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1 and GL 4A. For additional information on GL 1, see FAQ 1253.

Date Released- October 15, 2026