President of the United States, Donald J. Trump, issued on 1 May 2026 a new Executive Order aimed at strengthening the sanctions regime against individuals, entities, and financial institutions linked to the Government of Cuba, as well as those deemed responsible for alleged acts of repression, corruption, serious human rights abuses, or threats to U.S. national security and foreign policy.
The measure is adopted as an additional step within the framework of the national emergency declared under Executive Order 14380 of 29 January 2026, concerning threats attributed to the Cuban government. In this regard, the document reaffirms that the policies, practices, and actions of the Government of Cuba continue to be considered by the United States as an unusual and extraordinary threat to its national security and foreign policy.
The Executive Order expands the sanctions framework by establishing the blocking of all assets located in the United States, subsequently entering the United States, or within the possession or control of U.S. persons, that are related to foreign persons designated under its criteria. Such assets may not be transferred, paid, exported, withdrawn, or otherwise dealt with.
The measure targets non-U.S. entities operating in the energy, defence and related material, metals and mining, financial services, and security sectors, as well as any other sector of the Cuban economy that may be designated in the future by the Department of the Treasury in consultation with the Department of State. This formulation is notable as it grants the U.S. executive branch discretionary power to extend its application to additional economic sectors in the future, without the need to issue new executive orders for each additional sector.
It applies to entities controlled by or acting on behalf of the Government of Cuba or designated persons, as well as those providing financial, material, or technological support; leaders, officials, senior executives, or board members of the Cuban government or designated entities; agencies or instrumentalities of the Cuban state; persons allegedly involved in serious human rights abuses or corruption related to Cuba; and adult family members of designated individuals.
In financial matters, the Order introduces a specific provision for foreign financial institutions that have conducted or facilitated significant transactions for designated persons. In such cases, the Secretary of the Treasury, in consultation with the Secretary of State, may prohibit or strictly condition the opening or maintenance of correspondent or payable-through accounts in the United States, and may block the assets of the relevant foreign financial institution.
The Order also introduces immigration restrictions. In particular, it suspends entry into the United States, as immigrants or non-immigrants, of foreign persons who meet any of the designation criteria set out in the Order, unless such entry is deemed to be in the national interest of the United States.
Additionally, it prohibits transactions intended to evade or circumvent its provisions, as well as any conspiracy to violate them. It also restricts certain donations by U.S.-jurisdiction entities to designated entities, on the grounds that such actions could undermine the Executive’s ability to respond to the declared national emergency concerning Cuba.
Furthermore, the Order establishes that no prior notice is required for the designation of individuals or entities under the sanctions regime. In the view of the U.S. Executive, the ability to transfer funds or assets immediately could undermine the effectiveness of blocking measures if potential targets were notified in advance. Accordingly, competent authorities may proceed with inclusion or designation without prior notice, thereby reinforcing the immediate nature of the sanctions regime.
The prohibitions apply unless exemptions, licences, regulations, orders, or directives issued under the Order provide otherwise. It also expressly states that its provisions do not affect the validity of licences issued under Part 515 of Title 31 of the Code of Federal Regulations, relating to the Cuban Assets Control Regulations.
The Order is part of the current logic of progressive tightening of the embargo and the expansion of extraterritorial sanctions tools. Its most relevant features lie in the systematisation and broadening of designation criteria, the explicit inclusion of strategic economic sectors, the introduction of specific sanctions against foreign financial institutions, the consolidation of immigration restrictions linked to sanctions criteria, and the possibility of adopting inclusion or designation measures without prior notice, in order to preserve the immediate effectiveness of sanctions.
However, despite the apparent breadth of its provisions, its direct impact on non-U.S. operators must be assessed with caution. The Order is framed within U.S. law and primarily affects assets under U.S. jurisdiction, operations within U.S. territory, and relations with the U.S. financial system. Consequently, although it may generate indirect risks for international economic actors with exposure to the United States, in the case of European operators, for example, the Order does not in itself modify the EU legal framework applicable to their commercial or financial relations with Cuban entities.
In this context, the continued relevance of the European Union’s response remains evident, particularly through Council Regulation (EC) No. 2271/96, known as the Blocking Statute, which establishes a legal framework to protect EU operators from the extraterritorial effects of sanctions imposed by third countries, such as U.S. measures against Cuba.
Accordingly, these provisions do not directly affect nor condition commercial or financial operations between European and Cuban economic actors, particularly in the context of business-to-business (B2B) relations, which must continue to be assessed under EU law, applicable national legislation, relevant licences or authorisations, and the specific level of exposure of each transaction to the U.S. financial system.