President Donald Trump issued an Executive Order on May 1, 2026, establishing a new U.S. sanctions program targeting Cuba that supplements existing sanctions. The Order gives the U.S. Secretaries of State and Treasury the authority to impose sanctions on non-U.S. persons, including foreign financial institutions, for engaging in certain activities in Cuba or involving sanctioned Cuban persons. It thus creates significant new risks for non-U.S. persons with respect to dealings in or involving Cuba.