Appendix A to Part 516 - E.O. 14404 of May 1, 2026

Date issued: May. 01 2026

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TURBOFAC Commentary (665 words)

Notes:

[9-30-26 Update – this EO was implemented in the CFR in the Cuba Sanctions Regulations (31 CFR part 516. See 560.101 et seq)]

1) This EO, for the first time ever, authorizes the imposition of “secondary sanctions” on non-U.S. persons for dealings involving Cuba.

2) Notable aspects of the EO include:

(a) A broad range of Cuba-specific targeting authorities, including operating in “in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy,” and having “materially assisted…or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba.” (North Korea is currently only other government in the world of which the entirety is subject to such “material support” sanctions...