On June 4, 2026, the US Department of State announced a new round of designations under Executive Order 14404 (“EO 14404”) targeting five entities and five individuals for being “associated with developing, implementing, and funding the Cuban regime’s violent revolutionary network.” Secretary of State Marco Rubio issued a press statement explaining the purpose of these designations. Concurrent with these designations, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new…
On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which significantly expands the US sanctions framework targeting Cuba. EO 14404 imposed a modern US secondary sanctions regime targeting Cuba that is likely to encourage many non-US companies – particularly those with US assets/business and/or reliance on the US financial system –…
On January 29, 2026, President Trump signed Executive Order 14380, “Addressing Threats To the United States by the Government of Cuba” (the “Executive Order”), in which he declared a national emergency with respect to Cuba and authorized the United States to impose new tariffs on imports from countries that directly or indirectly supply oil to the Government of Cuba. The Executive Order is accompanied by a White House Fact Sheet outlining the administration’s national security…
On June 30, 2025, the White House reissued National Security Presidential Memorandum-5 (“2025 NSPM-5”) focused on Cuba policy that it published in largely the same form in the first Trump Administration (see the “2017 NSPM-5”). As acknowledged in Section 4(a) of the reissued document, much of the contents of the 2025 NSPM-5 was already implemented in the first Trump Administration pursuant to the 2017 NSPM-5. Along with 2025 NSPM-5, the White House issued a related…