Table of Contents
Executive Summary
On 4 June 2026, the State Department’s press release announced the inclusion on the Specially Designated Nationals and Blocked Persons List (SDN List) of five entities and five individuals linked to the Cuban regime.
The measure is adopted pursuant to Executive Order (EO) 14404, dated 1 May 2026, entitled “Imposition of Sanctions on Those Responsible for Repression in Cuba and Threats to US National Security and Foreign Policy”.
This order allows for the imposition of restrictions on individuals and organisations that meet specific criteria relating to internal repression and threats to US national security.
It is worth noting that this notification coincides with the expiration of the deadline—set for this past June 5—for international operators to definitively cease commercial operations with the military conglomerate GAESA, or otherwise proceed with the corresponding formal notification to the Office of Foreign Assets Control (OFAC).
Content and regulatory scope: Designated entities and individuals
The designations are divided into three main categories according to the role and means of financing or supporting the regime:
1. Action against the regime’s institutional and political apparatus. The following organisations associated with the development, execution and financing of operations carried out by the Cuban government are designated:
- Ministry of the Revolutionary Armed Forces of Cuba (MINFAR)
- Cuban Institute of Friendship with the Peoples (ICAP). An organisation founded in 1960 which, according to the US Department of State, supports Cuban intelligence and counter-intelligence activities.
- Amistur Cuba S.A.: A company primarily engaged in organising socio-political tourism and designated for being owned, controlled or acting directly or indirectly on behalf of ICAP.
- Committees for the Defence of the Revolution (CDR). According to the US Government, they operate under the direction of the Cuban Ministry of the Interior (already designated) and are described as a pillar of the state security apparatus.
2. Senior officials and members of their families
Furthermore, senior political officials and their immediate families are directly sanctioned:
- Miguel Díaz-Canel Bermúdez, in his capacity as President of Cuba, as well as his wife and son.
- Alejandro Castro, son of Raúl Castro, for acting on behalf of the Cuban Government and as a former head of the intelligence services, as well as his son.
3. Withdrawal of economic benefits
A specific designation is introduced for a company that generates significant profits for the Cuban regime and operates in the metallurgical and mining sectors. This is a gold mining joint venture established by an Australian and a Cuban company.
Legal perspective and implications of the sanctions
These sanctions have significant consequences for certain international operators:
- Asset freeze: All property and interests in property of designated persons and entities located in the US or in the possession or control of US persons are frozen and must be reported to the Office of Foreign Assets Control (OFAC).
- 50 per cent rule: The freezing automatically extends to any entity that is owned, directly or indirectly, 50 per cent or more, individually or jointly, by one or more blocked persons.
- General prohibition on transactions: US persons are prohibited from engaging in any transaction, contribution or provision of funds, goods or services by, for or for the benefit of those sanctioned, unless expressly authorised by a general or specific licence from OFAC.
- Risk to financial institutions and foreign companies: Non-US persons (including foreign banks) that engage in transactions with designated entities or operate in the Cuban energy, defence, metallurgical and mining, financial services or security sectors are exposed to a significant risk of being sanctioned.
- Cuban Assets Control Regulations (CACR): It is noted that all property blocked under the CACR remains in that status, and persons subject to US jurisdiction are prohibited from engaging in transactions involving assets in which Cuba or a Cuban national has an interest.
Conclusion
This new wave of designations under Executive Order 14404 consolidates the US strategy of multidimensional pressure, directly impacting not only the island’s military and intelligence structure, but also corporate vehicles for foreign investment (such as the gold mining sector) and the family circles of certain senior government officials. For international companies and financial institutions with cross-border operations, this scenario requires an immediate strengthening of their due diligence systems, a rigorous analysis of the corporate structures of their business partners, and a review of any direct or indirect exposure to the Cuban market.
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