1251. What does Executive Order (E.O.) 14404 of May 1, 2026, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy," do?
E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, "Addressing Threats to the United States by the Government of Cuba." E.O. 14404 authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on foreign persons determined to be involved in specified harmful activities related to Cuba, including:
*operating, or having operated in identified sectors of the Cuban economy (e.g., Cuba’s energy, defense and related materiel, metals and mining, financial services, and security sectors);
* acting for or on behalf of, or providing support to, the Government of Cuba or persons blocked pursuant to E.O 14404; and
* being responsible for or complicit in serious human rights abuse or corruption related to Cuba.
E.O. 14404 establishes a new Cuba-related sanctions program under the International Emergency Economic Powers Act (IEEPA) that is separate from, and in addition to, the Cuban Assets Control Regulations (CACR), 31 CFR part 515. All existing CACR prohibitions and authorizations remain in effect. E.O. 14404 also expressly states that prohibitions within and actions taken pursuant to E.O. 14404 do not affect the validity of licenses issued pursuant to the CACR. Additionally, on May 7, 2026, OFAC issued Cuba-related General License 1, "Transactions Authorized Pursuant to the Cuban Assets Control Regulations," authorizing all transactions prohibited by E.O. 14404 where transactions are authorized or exempt under the CACR. See FAQ 1253 for additional information.
While the United States has long maintained sanctions on Cuba and Cuban nationals pursuant to the CACR, E.O. 14404 broadens U.S. sanctions on Cuba to include authorizing sanctions on non-Cuban foreign persons for providing support to Cuba and on foreign financial institutions for conducting or facilitating significant transactions involving persons blocked pursuant to E.O. 14404. Foreign persons, including foreign financial institutions, should be aware of the new sanctions risk for engaging in certain conduct with Cuba as outlined in E.O. 14404.
Released on May 07, 2026
1) Refer generally to comments to EO 14404. This FAQ is a standard “what does [this new EO] do” FAQ that does not provide much in the way of interpretive guidance.