Cuba General License 1 - Transactions Authorized Pursuant to the Cuban Assets Control Regulations (May 07, 2026)

Date issued: May. 07 2026

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TURBOFAC Commentary (429 words)

Notes:

1) EO 14404 and the CACR are separate sanctions authorities, one issued pursuant to IEEPA and the other pursuant to TWEA, though “Sections 2(b) and 4(c) of E.O. 14404 state that the relevant prohibitions found in E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR” (FAQ 1252). More specifically, section 2 of EO 14404, which is titled “sanctionable conduct” and houses designation criteria but also contains the substantive prohibitions for dealings with blocked persons, says “[t]he prohibitions in subsection (a) of [section 2] apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that are issued pursuant to this order, and notwithstanding any contract entered into or...