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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On January 29, 2026, President Donald Trump issued <a href="https://www.federalregister.gov/public-inspection/2026-02250/cuba-efforts-to-address-threats-to-us-eo-14380" target="_blank" rel="noreferrer noopener">Executive Order 14380</a> to impose an additional ad valorem duty on goods from countries that directly or indirectly sell or otherwise provide oil&mdash;that is, crude oil or petroleum products&mdash;to Cuba.&nbsp;Although the executive order, which took effect on January 30, 2026, appears broad in scope, it clarifies that the Secretary of Commerce will determine which countries directly or indirectly sell or otherwise provide oil to Cuba and convey that information to the Secretary of State, who will then propose the additional ad valorem duty rate for President Trump&rsquo;s consideration.
Executive Order (&ldquo;EO&rdquo;) 14380 is reminiscent of other EOs issued by President Trump imposing duties on countries that trade, directly or indirectly, in certain oil.&nbsp;For example, in March 2025, President Trump signed <a href="https://www.federalregister.gov/documents/2025/03/27/2025-05440/imposing-tariffs-on-countries-importing-venezuelan-oil" target="_blank" rel="noreferrer noopener">EO 14245</a>, which imposed a 25% tariff on countries that purchase oil from Venezuela directly or indirectly (see <a href="https://www.thompsonhinesmartrade.com/2025/03/trump-signs-eo-imposing-an-additional-25-tariff-on-countries-that-buy-venezuelan-oil/">Update of March 25, 2025</a>).&nbsp;Similarly, in August 2025, President Trump issued <a href="https://www.federalregister.gov/documents/2025/08/11/2025-15267/addressing-threats-to-the-united-states-by-the-government-of-the-russian-federation" target="_blank" rel="noreferrer noopener">EO 14329</a> to impose a 25% tariff against India for buying Russian oil, alleging these purchases improperly propped up Russia&rsquo;s ongoing efforts to undermine the sovereignty and territorial integrity of Ukraine (see <a href="https://www.thompsonhinesmartrade.com/2025/08/president-trump-announces-additional-tariffs-on-india-for-russian-federation-oil-purchases/">Update of August 7, 2025</a>).&nbsp;Like his previous oil-related EOs, EO 14380 invokes the International Emergency Economic Powers Act (IEEPA) as authority to levy the additional tariff.
Under IEEPA, tariffs may not be imposed absent an underlying national emergency, and EO 14380 declares such an emergency with respect to Cuba that suggests which countries are President Trump&rsquo;s focus.&nbsp;According to the EO, &ldquo;[t]he [Cuban] regime aligns itself with&mdash;and provides support for&mdash;numerous hostile countries, transnational terrorist groups, and malign actors adverse to the United States,&rdquo; specifically identifying China, India, and Russia (as well as groups such as Hamas and Hezbollah).
The EO further warns that if EO 14380 &ldquo;is not effective in dealing with the national emergency declared in this order,&rdquo; additional action may be warranted and taken.

President Trump Imposes Additional Tariff on Countries That Sell Oil to Cuba

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