United States Announces New Cuba-Related Sanctions Program
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.
Five Key Takeaways From 2025 U.S. Sanctions Enforcement
U.S. sanctions enforcement activity in 2025 underscored the U.S. government’s continued commitment to robust enforcement of the various sanctions programs primarily administered and enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s 2025 enforcement actions also signaled the agency’s substantive priorities and, perhaps most important, highlighted its compliance expectations.