OFAC Adds Cuba's CUPET To SDN List. No Surprise, Except Why Decision Took So Long Given Case Before SCOTUS.

Office of Foreign Assets Control
United States Department of the Treasury
Washington DC
11 June 2026

Specially Designated Nationals List Updates

The following entity has been added to OFAC's SDN List:

”UNION CUBA PETROLEO (a.k.a. CUPET), Avenida Salvador Allende No. 666, Entre Oquendo y Soledad, Havana 10300, Cuba; Organization Established Date 25 Mar 1992; Target Type State-Owned Enterprise; Entity Code 2605 (Cuba) [CUBA-EO14404].”

Spring, Texas-based Exxon Mobil Corporation (2025 revenue approximately US$332 billion) filed a Title III Libertad Act lawsuit in 2019 against Republic of Cuba government-operated Corporacion Cimex S.A. and Republic of Cuba government-operated Union Cuba Petroleo (CUPET).

Exxon Mobil Corporation has the 8th largest certified claim against the government of the Republic of Cuba: US$71,611,002.90 and US$173,157.12.

The Trump-Pence Administration (2017-2021) on 2 May 2019 made operational Title III of the Cuban Liberty and Democratic Solidarity Act of 1996 (known as “Libertad Act”). 

Title III authorizes lawsuits in United States District Courts against companies and individuals who are using a certified claim or non-certified claim where the owner of the certified claim or non-certified claim has not received compensation from the Republic of Cuba or from a third-party who is using (“trafficking”) the asset.  

EXXON MOBIL CORPORATION V. CORPORACION CIMEX, S.A. (Cuba) et al., CORPRACION CIMEX, S.A. (Panama), AND UNION CUBA-PETROLEO [1:19-cv-01277; Washington DC].  31 October 2021 to Court of Appeals for the District of Columbia (21-7127).  Case pending before United States Supreme Court.

Steptoe (plaintiff)
Cross Castle, PLLC (plaintiff- withdrawn)
Rabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C. (defendant)

EXXON MOBIL CORPORATION V. CORPRACION CIMEX, S.A. (Panama), AND UNION CUBA-PETROLEO [1:19-cv-01277; Washington DC].  31 October 2021 to Court of Appeals for the District of Columbia (21-8010).  Case pending before United States Supreme Court.

Steptoe (plaintiff)
Cross Castle, PLLC (plaintiff- withdrawn)
Rabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C. (defendant)

24-699 
EXXON MOBIL CORP. V. CORPORACION CIMEX
DECISION BELOW: 111 F.4th 12
CERT. GRANTED 10/3/2025


QUESTION PRESENTED: In 1960, the Cuban government confiscated the property of American nationals and transferred it to state-owned enterprises. After years without a diplomatic resolution, Congress enacted the Helms-Burton Act, which created a damages action for American nationals against "any person ... that traffics in" such confiscated property. 22 U.S.C. § 6082(a)(1). The Act defines "person" to include "any agency or instrumentality of a foreign state," id. § 6023(11), and expressly contemplates "judgment[s] against an agency or instrumentality of the Cuban Government," id. § 6082(d). The question presented is: Whether the Helms-Burton Act abrogates foreign sovereign immunity in cases against Cuban instrumentalities, or whether parties proceeding under that Act must also satisfy an exception under the Foreign Sovereign Immunities Act.  LOWER COURT CASE NUMBER: 21-7127, 22-7019, 22-7020

Links To Related Analysis

Link: U.S. Supreme Court Rules 8-1 For Plaintiff, Havana Docks Corporation, In US$440 Million Lawsuit Against Four Cruise Lines May 21, 2026

Link: Transcripts And Recordings Of SCOTUS Libertad Act Title III Arguments: Havana Docks And Exxon Mobil February 24, 2026

Link: US Supreme Court Permits US Solicitor General To Deliver Ten Minute Argument On 23 February 2026 Supporting Exxon Mobil Corporation Against Cuba Government In Libertad Act Lawsuit January 27, 2026

Link: Foreign Sovereign Immunities Act Is Focus Of Two Libertad Act Lawsuits At DC Court Of Appeals: Exxon Mobil Versus Cimex S.A. (Cuba), Cimex S.A. (Panama), Union Cuba-Petroleo January 20, 2022

Link: U.S. Supreme Court Agrees To Hear Two Cuba Libertad Act Cases. Trump Administration Supports Both Plaintiffs. October 03, 2025