Update to OFAC's list of Specially Designated Nationals (SDN) and Blocked Persons; Issuance of Cuba-related General License and Frequently Asked Questions

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 the Cuban economy: (1) energy; (2) defense and related materiel; (3) metals and mining; (4) financial services; and (5) security. E.O. 14404 also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to determine that the prohibitions in section 2(a)(i)(A) of E.O. 14404 apply to additional sectors of the Cuban economy.

The identification of these sectors exposes foreign persons that operate or have operated in such sectors to sanctions risk; however, it does not automatically impose sanctions on all persons who operate or have operated in those sectors. Only foreign persons determined pursuant to E.O. 14404 to operate or have operated in an identified sector are subject to sanctions under this criterion.

Persons should also note that E.O. 14404 is separate from the Cuban Assets Control Regulations (CACR), 31 CFR part 515. A person that is not sanctioned pursuant to E.O. 14404 may still be subject to CACR prohibitions or restrictions. For further information regarding the CACR prohibitions, please see FAQs 1252, 1254, and 1255.

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 against foreign persons determined to meet one or more of the criteria in E.O. 14404. Persons sanctioned under the CACR are only subject to sanctions under E.O. 14404 if such persons are separately determined by the Secretary of the Treasury or the Secretary of State to meet the criteria under E.O. 14404.

Persons listed on OFAC's Specially Designated Nationals and Blocked Persons List may be identified under one or more sanctions authorities.

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 percent or greater interest, through June 5, 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 wind down transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50 percent or greater interest, before June 5, 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 GAESA, a Cuban military-controlled entity, absent OFAC authorization. GAESA has been identified on the List of Specially Designated Nationals and Blocked Persons (SDN List) and the State Department-administered Cuba Restricted List since December 21, 2020. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving GAESA, including in connection with a foreign person's wind down of activities with GAESA, unless separately authorized by OFAC.

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 issued pursuant to the CACR. GL 1 is intended to ensure activity authorized or exempt under the CACR is not interrupted if a foreign person already blocked or otherwise identified under the CACR is also blocked pursuant to E.O. 14404, such as Grupo de Administración Empresarial S.A. (GAESA). In such cases, no additional OFAC authorization beyond GL 1 would be required to engage in CACR-authorized activities.

GL 1 does not expand the scope of any authorization or exemption under the CACR. Any transaction must continue to comply with all relevant conditions and limitations as provided in the CACR to be authorized under GL 1. As with all OFAC GLs, GL 1 is "self-executing," meaning that persons who assess that their transactions fall within the scope of the authorization may proceed without further assurance from OFAC. Transactions prohibited by E.O. 14404 require additional OFAC authorization if not authorized or exempt under the CACR.

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 statutes. These authorities function in parallel. E.O. 14404 establishes the authority for a new Cuba-related sanctions program that includes blocking sanctions and certain less-than-blocking sanctions against foreign persons determined to meet one or more of the criteria in E.O. 14404.

Simultaneously, OFAC continues to administer the CACR, including its prohibitions, authorizations, and exemptions. OFAC maintains the authority to identify certain persons on the List of Specially Designated Nationals and Blocked Persons (SDN List) under the CACR, including persons acting for or on behalf of the Government of Cuba. However, the CACR continues to operate as a jurisdictional sanctions program focused specifically on Cuba and Cuban nationals.

Furthermore, Sections 2(b) and 4(c) of E.O. 14404 state that the relevant prohibitions found in E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR.

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 foreign persons determined to be involved in specified harmful activities related to Cuba, including: operating, or having operated in identified sectors of the Cuban economy (e.g., Cuba’s energy, defense and related materiel, metals and mining, financial services, and security sectors); acting for or on behalf of, or providing support to, the Government of Cuba or persons blocked pursuant to E.O 14404; and being responsible for or complicit in serious human rights abuse or corruption related to Cuba.  E.O. 14404 establishes a new Cuba-related sanctions program under the International Emergency Economic Powers Act (IEEPA) that is separate from, and in addition to, the Cuban Assets Control Regulations (CACR), 31 CFR part 515. All existing CACR prohibitions and authorizations remain in effect. E.O. 14404 also expressly states that prohibitions within and actions taken pursuant to E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR. Additionally, on May 7, 2026, OFAC issued Cuba-related General License 1, "Transactions Authorized Pursuant to the Cuban Assets Control Regulations," authorizing all transactions prohibited by E.O. 14404 where transactions are authorized or exempt under the CACR. See FAQ 1253 for additional information.

While the United States has long maintained sanctions on Cuba and Cuban nationals pursuant to the CACR, E.O. 14404 broadens U.S. sanctions on Cuba to include authorizing sanctions on non-Cuban foreign persons for providing support to Cuba and on foreign financial institutions for conducting or facilitating significant transactions involving persons blocked pursuant to E.O. 14404. Foreign persons, including foreign financial institutions, should be aware of the new sanctions risk for engaging in certain conduct with Cuba as outlined in E.O. 14404.

Additions To SDN List

LASTRES MORERA, Ania Guillermina, Marianao, Havana, Cuba; DOB 19 Aug 1962; POB Marianao, Cuba; nationality Cuba; Gender Female (individual) [CUBA-EO]. 

GRUPO DE ADMINISTRACION EMPRESARIAL S.A. (a.k.a. GAESA; a.k.a. "GRUPO GAE"), Edificio de la Marina, Avenida Del Puerto Y Brapia, Havana, Cuba; Organization Established Date 28 Feb 1999; Organization Type: Activities of holding companies [CUBA]. -to- GRUPO DE ADMINISTRACION EMPRESARIAL S.A. (a.k.a. GAESA; a.k.a. "GRUPO GAE"), Edificio de la Marina, Avenida Del Puerto Y Brapia, Havana, Cuba; Organization Established Date 28 Feb 1999; Organization Type: Activities of holding companies; Entity Code 60446 (Cuba) [CUBA] [CUBA-EO]. 

MOA NICKEL SA, Cuba [CUBA]. -to- MOA NICKEL SA, Moa, Cuba; Organization Established Date 1994; Organization Type: Mining of other non-ferrous metal ores [CUBA] [CUBA-EO].