On July 23, 2026, the US Department of State designated multiple entities and individuals in Cuba, and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new Cuba-related general licenses.
The actions are intended to further restrict revenue streams supporting the Cuban government, including activities tied to the energy sector, sanctions evasion networks, financial services, and Cuba’s overseas medical missions program.
The designations and general licenses were issued under Executive Order 14404 of May 1, 2026, which authorizes sanctions targeting persons linked to repression in Cuba and other activities deemed to threaten US national security and foreign policy.
The New SDN Designations
The Department of State designated three entities for operating or having operated in the energy sector of the Cuban economy, four entities associated with Cuban military conglomerate Grupo de Administración S.A.’s alleged attempts to shield its assets and revenue streams from US sanctions through corporate restructuring and third-party intermediaries (including a Guernsey-based real estate firm called CEIBA Investments Limited (“CEIBA”)), and four individuals and entities for their roles in administering the Cuban government’s labor-export program, including its overseas medical missions, which the State Department determined involves a “policy or pattern of forced labor.”
OFAC Issues New Cuba-Related General Licenses
In conjunction with the designations, OFAC issued three new Cuba-related general licenses:
- Cuba General License 2: authorizing transactions that are ordinarily incident and necessary to the wind down of any transaction involving CEIBA or any entity in which CEIBA owns, directly or indirectly, a 50 percent or greater interest until August 22, 2026.
- Cuba General License 3: authorizing, until August 22, 2026, transactions that are ordinarily incident and necessary to:
- the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by CEIBA or any entity in which CEIBA owns, directly or indirectly, a 50 percent or greater interest, (“Covered Debt or Equity”), to a non-US person;
- facilitating, clearing, and settling trades of Covered Debt or Equity that were placed prior to 4:00 p.m. EDT on July 23, 2026; and
- the wind down of derivative contracts entered into prior to 4:00 p.m. EDT on July 23, 2026 that (i) include CEIBA or any entity in which it owns, directly or indirectly, a 50% or greater interest, as a counterparty or (ii) are linked to Covered Debt or Equity.
Any payments to blocked persons made pursuant to this general license must be deposited into a blocked account, and the authorization does not extend to transactions involving blocked persons not named in the general license unless they are separately authorized by OFAC.
- Cuba General License 4: authorizing certain transactions that are ordinarily incident and necessary to the conduct of the official business of third-country diplomatic or consular missions located in Cuba.
These actions represent the continued expansion of the US government’s Cuba sanctions strategy under Executive Order 14404 and indicate a focus on Cuba’s energy and financial services sectors, alleged sanctions evasion activity, and third-country actors facilitating revenue generation for the Cuban government.
