Time For Trump-Vance Administration To Authorize OFAC To License U.S. Banks To Open Branches In Havana

And For Government Of Cuba To Welcome It… Quickly

If U.S. Company Completes Takeover Of Nickel & Cobalt Mining Operation In Cuba, It Will Need To Move Funds From And To Cuba

In 2025, More Than US$700 Million For Authorized Commercial Transactions Moved From The Republic Of Cuba To The United States And From The United States To The Republic Of Cuba

Might First American Bank In Illinois Be A Candidate To Open Branch In Havana? Three Florida-Based Banks Could Be Candidates

The Trump-Vance Administration (2025-2029) has focused upon reducing and removing Republic of Cuba government-operated companies and Republic of Cuba government-operated financial institutions from their roles in the commercial, economic, and financial infrastructure of the Republic of Cuba.

In February 2026, the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury authorized United States-based companies to export fuels directly to the re-emerging private sector in the Republic of Cuba.

Link: With New BIS Guidance For Fuel, Gas, Petroleum Product Exports To Cuba, Trump Administration Confirms There Is A Private Sector In Cuba And U.S. Companies May Engage. Members Of Congress Not Pleased. February 25, 2026

In May 2022, the OFAC authorized the direct investment in and direct financing to a privately-owned company owned by a Republic of Cuba national residing in the Republic of Cuba.

The easier the mechanisms to receive payment, the more fuels (and other products) will be exported, and the more revenue will in turn flow to United States-based companies.

If the Trump-Vance Administration wants to jump-start the re-emerging private sector in the Republic of Cuba and jump-start the interest in the Republic of Cuba by the private sector in the United States, then permit financial institutions subject to United States jurisdiction to own, manage, and operate full-service branches in the city of Havana.

The authorization by the OFAC could be contingent upon the Central Bank of the Republic of Cuba issuing a license for financial institutions subject to United States jurisdiction to own, manage, and operate full-service branches in the Republic of Cuba.

“The aggression of the U.S. against Cuba has taken on the unbelievable form of prohibiting citizens and businesses from any country from engaging in certain commercial ties with Cuba. The stance of the governments of these citizens and businesses does not matter. They are left unprotected under the coercive arm of the U.S.” Carlos Fernandez de Cossio, Deputy Minister of Foreign Affairs of the Republic of Cuba

The Obama-Biden Administration (2009-2017) authorized United States-based financial institutions to have correspondent accounts with Republic of Cuba government-operated financial institutions. However, Republic of Cuba government-operated financial institutions were not authorized to have correspondent accounts with United States-based financial institutions.

“Correspondent banking is an arrangement where one bank (the correspondent) holds deposits for and provides payment or settlement services to another bank (the respondent). It serves as the vital plumbing for cross-border transactions and foreign currency exchanges, allowing smaller or regional institutions to offer global services without establishing international branches.”

If a financial institution subject to United States jurisdiction has a full-service branch in the Republic of Cuba, it would then establish correspondent account operations within its existing efficient, secure, and transparent Information Technology (IT) framework.

Given the recurring operational issues with Republic of Cuba government-operated financial institutions, quite likely there would be an overwhelming welcoming by the re-emerging private sector in the Republic of Cuba for a full-service branch of a financial institution subject to United States jurisdiction. Customers would know their deposits are safe, their transactions secure, their online banking functions, and their debit cards and credit cards can access Automated Teller Machine (ATM) and online banking services.

Currently, funds authorized by the OFAC, Bureau of Industry and Security (BIS) of the United States Department of Commerce, and United States Department of State, moving from the United States to the Republic of Cuba and from the Republic of Cuba to the United States must use financial institutions located in third countries. Meaning, for each transaction, there is an additional and unnecessary fee.

The total value of agricultural and food products exported from the United States to the Republic of Cuba, on a cash basis as required by the Trade Sanctions Reform and Export Enhancement Act (TSREEA) of 2000 exceeds US$8.3 billion.
The total value of healthcare products exported from the United States to the Republic of Cuba using provisions of the Cuban Democracy Act (CDA) of 1992 exceeds US$39 million.
Since 2015, the total value of products exported from the United States to the Republic of Cuba for use by the re-emerging private sector exceeds US$470 million. From 2025 through 2026, the value exceeds US$270 million.
Other payments from the United States to the Republic of Cuba include patent registrations, trademark registrations, estate settlements, and overflight fees. Other payments from the Republic of Cuba to the United States include agricultural equipment, assembly equipment, fuels, hardware, manufacturing equipment, motor vehicles, retail products, and solar panels.

In 2017, Deere & Company (2025 revenues approximately US$45.6 billion) established a distribution center in the Republic of Cuba, and San Juan, Puerto Rico-based RIMCO, the Republic of Cuba distributor for Irving, Texas-based Caterpillar Inc. (2025 revenues US$67.6 billion) established a distribution center.

Dallas, Texas-based Gillon Capital, LLC is seeking to control 55% of Toronto, Canada-based Sherritt International Corporation which has cobalt, nickel, and energy operations in the Republic of Cuba. The transaction would permit settlement of one of the largest of the 5,913 claims certified by the United States Foreign Claims Settlement Commission (USFCSC) within the United States Department of Justice DOJ) along with additional supplies of cobalt and nickel. CU-2619: MOA Bay Mining Company, Improved Real Property, Oriente, Republic of Cuba, US$88,349,000.00. Link To Claim Filing In PDF Format

A successful transaction by Gillon Capital LLC will require the regular movement of millions of dollars from the Republic of Cuba and to the Republic of Cuba.

In 2019, Chicago, Illinois-based First American Bank (2026 assets approximately US$8 billion) acquired Miami, Florida-based Continental National Bank (2019 assets approximately US$490 million), the first national chartered bank in the United States owned by an individual of Cuban descent.

Other Florida-based financial institutions with connectivity to individuals of Cuban descent include Coral Gables, Florida-based Bradesco BAC Florida Bank; Miami, Florida-based Ocean Bank; and Doral, Florida-based U.S. Century Bank.

El Toque (excerpts): “In May 2025, the Official Gazette of the Republic of Cuba published Resolution 28/2025 from the Central Bank of the Republic of Cuba (BCC), granting Novabank S.A., a fully foreign-owned corporate bank, an indefinite license to operate as a financial intermediary on the island. The license authorizes Canadian firms Groupe Novinvest Inc. and Les Fonds Génération Nova Inc., both established in 2022, to create the new financial institution. Novabank S.A. will offer services exclusively to legal entities. Both Canada-based companies are affiliated with Principal, Quebec-based Le Groupe Lussier which has more than thirty years operating in the Republic of Cuba. Novabank S.A. is authorized to engage with micro, small, and medium-sized enterprises (MSMEs) and non-agricultural cooperatives (CNAs). Novabank S.A. is not a Canada-based bank operating in the Republic of Cuba. It is a Republic of Cuba-based financial institution created to operate exclusively in the Republic of Cuba. The capital originates with Canada-based investors, the bank is not a branch or subsidiary of any existing Canada-based bank.”

“In 2023, the BCC authorized Spain-based Alto Cedro Banco Corporativo S.A. to operate within the Republic of Cuba. The BCC has authorized Moscow, Russian Federation-based Novikombank AO to operate in the Republic of Cuba. Novikombank AO is a subsidiary of Moscow, Russian Federation-based State Corporation for the Promotion of the Development, Manufacture, and Export of High-Tech Products (ROSTEC) created with Tolyatti, Russian Federation-based JSC Avtovaz, which has since relinquished its shareholding.” The OFAC lists Novikombank AO as a Specially Designated National (SDN).

Link To Related Analyses

Canada's Sherritt Questions "ability to continue" While OFAC Considers U.S. Company License Application To Save Company, Invest In Cuba, Settle A Certified Claim, Export Nickel And Cobalt To U.S. June 26, 2026

Exxon Prevails At U.S. Supreme Court Against Cuba Government Companies. "We conclude that the Helms-Burton Act itself abrogates the sovereign immunity of Cuban agencies and instrumentalities" June 23, 2026

Revisionism: In USA Today Cuba Interview, Biden Administration White House And State Department Official "Forgets" Opposing Critical Private Sector Banking Need March 09, 2026

With New BIS Guidance For Fuel, Gas, Petroleum Product Exports To Cuba, Trump Administration Confirms There Is A Private Sector In Cuba And U.S. Companies May Engage. Members Of Congress Not Pleased. February 25, 2026

Arrest Of "Super Mule" In Tampa For Illegally Transporting US$100,000.00 To U.S. From Cuba Not Surprising… May Have Transported US$4.5 Million In Last Nine Months. February 07, 2024

State Department, NSC, OFAC, BIS, USDA Don't Understand Requirements For Financial Plumbing To Function Efficiently. They Excel In Creating, Maintaining, And Defending Clogs. May 16, 2023

Logic From U.S. Department Of State: If We Permit It, Cuba Might Not Use It, So We Won’t Permit It. And, Yes, No One Asked Cuba. And, No One Asked U.S. Banks, Companies. May 01, 2023

Biden-Harris Administration Re-Engagement With Cuba’s Re-Emerging Private Sector Brings Urgency To Re-Authorization Of Direct Correspondent Banking, U-Turn Transactions. One-Way Does Not Work. October 06, 2022

The Ketchup Is Out Of The Bottle... Cuba Authorizes Direct Equity Investments (And Direct Financing) To Privately-Owned Companies. Now, Will Cuba Make The Regulations Realistic Or Full Of Barriers? July 22, 2022

Now The Hard Part For Cuba: Implementing Quickly Transparent, Equal-For-All, MSME Investment & Financing Regulations. No Limitations. No Selectivity. No Orwellian Process. August 04, 2022

LINK TO COMPLETE ANALYSIS IN PDF FORMAT