Seven Years, Executive Orders, Lawsuits, Decisions, Settlements Have No Impact

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Solidarity Of Collective Weakness Or Acceptance Of Political Impotence?

Never Recovered From Not Issuing The RFP

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Neither the leadership of the Brussels, Belgium-based European Commission (EC) nor leadership of the Brussels, Belgium-based European Council (EC) nor members of the twenty-seven country Brussels, Belgium-based European Union (EU) taken any decision to add Trump-Vance Administration (2025-2029) Executive Order 14404 to the Annex to its Blocking Statute that includes specific extraterritorial measures, including the Cuban Liberty and Democratic Solidarity Act of 1996 (known as “Libertad Act”) and Cuban Assets Control Regulations (CACR) issued by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury.

EU: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.

Thus, there is no requirement under the EU blocking statute (Council Regulation (EC) No. 227/96) for Europe-based companies to adhere to Article 5 of the statute and resist the Executive Order’s secondary sanctions through noncooperation in providing information (e.g. wind -down of activity in Cuba); and in noncompliance with the Order’s coerced breach of European companies’ contracts and investment agreements with Republic of Cuba government-controlled (state) enterprises such as CUPET and GAESA and their affiliates.

From the OFAC: “As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.” Their assets are blocked, and U.S. persons are generally prohibited from dealing with them.”

12 June 2026: “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].”
7 May 2026: “GRUPO DE ADMINISTRACION EMPRESARIAL S.A. (GAESA), pursuant to section 2(a)(i)(A) of E.O. 14404, for operating or having operated in the financial services sector of the Cuban economy,” has been added to OFAC’s SDN List.
21 December 2020: “Grupo de Administración Empresarial S.A. (GAESA) is a Cuban military-controlled umbrella enterprise with interests in the tourism, financial investment, import/export, and remittance sectors of Cuba’s economy. GAESA’s portfolio includes businesses incorporated in Panama to bypass CACR-related restrictions,” has been added to the OFAC’s SDN List.

In December 2019, the EU confirmed its intention to issue a Request For Proposal (RFP) to law firms in the United States to be retained to file “amicus curiae” (friend-of-the-court) motions and other motions on behalf of each Libertad Act Title III lawsuit defendant who is domiciled in the EU. At that time, there are nine (9) EU-based companies listed as defendants or listed in lawsuits as having been contacted by plaintiff attorneys as a prelude to listing as a defendant. The EU never issued the RFP.

In 2019, the Trump-Pence Administration (2017-2021) made operational Title III and further implemented Title IV of the Cuban Liberty and Democratic Solidarity Act of 1996 (known as “Libertad Act”). Link To Title III Lawsuit Filing Statistics

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.
Title IV restricts entry into the United States by individuals who have connectivity to unresolved certified claims or non-certified claims. One Canada-based company and one Spain-based company are currently known to be subject to this provision based upon a certified claim and non-certified claim.

Link: Impacting Cuba? Booking Holdings Inc. And Booking.com B.V. Reach Settlements In Five U.S. Libertad Act Title III Lawsuits. Six Of 45 Lawsuits Filed Since 2019 Have Full Or Partial Settlements. May 15, 2024

Link: Will G7 Discuss Cuba? Three Have Companies Impacted By Trump Administration Decisions Beginning In 2019 And Accelerating In 2026. Ten Located In EU. Probably Giving Carte Blanche. June 16, 2026

Suspension History

Title III was suspended every six months since the Libertad Act was enacted in 1996- by President William J. Clinton (1993-2001), President George W. Bush (2001-2009), President Barack H. Obama (2009-2017), and through the first two years of President Donald J. Trump (2017-2021). President Joseph Biden (2021-2025) suspended again on 14 January 2025. On 20 January 2025, President Donald J. Trump (2025-2029) reversed the suspension.

On 16 January 2019, Mike Pompeo, United States Secretary of State, reported a suspension for forty-five (45) days.
On 4 March 2019, Secretary Pompeo reported a suspension for thirty (30) days.
On 3 April 2019, Secretary Pompeo reported a further suspension for fourteen (14) days through 1 May 2019.
On 17 April 2019, the Trump Administration reported that it would no longer suspend Title III.
On 2 May 2019, certified claimants and non-certified claimants were permitted to file lawsuits in United States courts.

Link To Related Analysis

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Legislation Introduced To Amend Cuba Libertad Act To Expand Who Can Sue. What Appellate Court Judge Said "despite a very clear intent, [Congress] drafts poorly. That is what I think happened here." May 22, 2026

Unfolding Trump-Vance Administration Strategy For Cuba: Eleven Focuses. Do Not Be Shocked If President Diaz-Canel Of Cuba Visits The White House May 18, 2026

Two EU-Based Shipping Companies Suspend Cuba Operations. One Settled Libertad Act Lawsuit And The Other Owns Florida International Terminal In Port Everglades. Will EU Do Anything? May 16, 2026

Libertad Act Lawsuit Against Iberostar Of Spain Returns To Circuit Court. International Comity Does Not Tolerate Inaction For Three Years. Iberostar, IHG Forge Alliance- Except Cuba Properties. March 01, 2023

With Appeals Court Ruling In Iberostar Of Spain Libertad Act Lawsuit, Why Would Any Defendant Subject To European Union Jurisdiction Waste Their Time Seeking Guidance From European Commission? November 22, 2022

Iberostar Files 25th Notice To Court. Judge Waiting 730 Days For European Commission To Respond. Patience Waning For Judge? Deadline Notice Likely. April 15, 2022

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In Brussels Will U.S. Secretary Of State Blinken Discuss Cuba, Libertad Act And Venezuela With EC/EU Officials? Will He Rebuff, Sway Or Be Swayed? Quid Pro Quo? March 23, 2021

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