OFAC FAQ (Current) # 1258 - Cuba Sanctions

Date issued: Jun. 04 2026

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TURBOFAC Commentary (251 words)

Notes:

1) Compare FAQ # 1254. This FAQ clarifies the relationship between the secondary sanctions/derivative designation provisions of EO 14404. GAESA, a large government-owned entity with ownership of many other entities in Cuba, was blocked pursuant to EO 14004 on May 7, 2026. OFAC now clarifies that “[s]anctions risk also extends to transactions with any entity in which GAESA, MININT, or MINFAR own, directly or indirectly, a 50 percent or greater interest,” and that “[n]on-U.S. persons should consider conducting enhanced due diligence to inform a risk-based approach to transactions with GAESA, MININT, MINFAR, or any entity in which they own, directly or indirectly, a 50 percent or greater interest.” Consistent with U.S. Sanctions Target Cuba’s Military Regime, Elites (Press Statement), OFAC’s emphasis on the question of whether a given entity is blocked pursuant to the 50 Percent Rule...