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.
FinCEN, Office of Foreign Assets Control Propose Anti-Money-Laundering Program and Sanctions Requirements for Stablecoin Issuers
The U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) (collectively Treasury) issued a joint notice of proposed rulemaking on April 8, 2026, to implement the anti-money-laundering (AML) and sanctions compliance provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), establishing a regulatory framework for permitted payment stablecoin issuers (PPSIs), hereinafter collectively “the proposed rule.”[1] The proposed rule does not address the GENIUS Act’s customer identification program (CIP) requirements, which are expected to be the subject of a separate rulemaking.
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.