On September 30, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented new sanctions on Cuba and formally amended the existing Cuban Assets Control Regulations (CACR). In May 2026, President Donald Trump issued Executive Order (EO) 14404 titled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.” The new Cuba sanctions regulations are directly related to this EO. See SmarTrade Update of May 4, 2026.
OFAC has issued a Final Rule in the Federal Register effective September 30, 2026, that fully implements EO 14404 by introducing new sanctions on Cuba at 31 C.F.R. Part 516. In the Final Rule, OFAC acknowledges that it is publishing these new Cuba sanctions regulations “in abbreviated form at this time for the purpose of providing immediate guidance to the public. OFAC intends to supplement this part 516 with a more comprehensive set of regulations, which may include additional interpretive guidance and definitions, general licenses, and other regulatory provisions.” All transactions prohibited pursuant to EO 14404 are prohibited under the new Cuba Sanctions Regulations.
The new Cuba Sanctions Regulations also allow for sanctions against foreign financial institutions (FFI) if such FFI conduct or facilitate any significant transaction or transactions for or on behalf of any person whose property or interests in property are blocked by these sanctions.
Note that other Cuba-related sanctions regulations are contained in 31 C.F.R. Part 515 and remain in effect, although OFAC has also issued on September 30, 2026, revisions to these regulations. Among other things, the revisions to Part 515:
- add a prohibition on indirect financial transactions with entities or sub-entities on the Cuba Restricted List;
- amend other authorizations related to financial transactions, including removing an authorization for “U-Turn” transactions; and,
- amend authorizations related to travel and related transactions, including removing authorizations for group people-to-people travel, educational activities, and professional meetings in Cuba.
These amended regulations also allow the Secretary of State to add to the Cuba Restricted List “any entities or subentities that are under the control of, or act for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel and with which direct or indirect financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba.”
OFAC also issued five new, Cuba-related Frequently Asked Questions (FAQs 1271–1275) addressing the above-mentioned revisions to the CACR, as well as amending 29 other Cuba-related FAQs.
For additional background, see also President Trump’s reissued National Security Presidential Memorandum (NSPM-5) to address U.S. policy towards Cuba that was published on June 30, 2025. See SmarTrade Update of July 3, 2025.