President of the United States Donald J. Trump has issued an update to the National Security Presidential Memorandum (NSPM-5), reinforcing the strategic line of U.S. foreign policy toward the Republic of Cuba. This new approach consolidates measures aimed at restricting economic ties with the Cuban government, as well as its state, military, intelligence, and security entities or authorities. It also announces the inclusion and forthcoming publication of an updated official list of Cuban entities with which direct or indirect commercial and financial transactions will be prohibited.
The document likewise reaffirms the commitment to strengthening the economic embargo imposed on the island since 1962, and expresses clear opposition to any international initiative, particularly within the United Nations system, advocating for its lifting. This stance confirms the intention to maintain and intensify existing sanctions as an instrument of political pressure.
In terms of migration and travel mobility, additional controls are introduced targeting U.S. citizens travelling to Cuba under authorised categories, particularly those related to non-academic educational activities and “people-to-people” support programs. These measures will require detailed documentation of itineraries, as well as audits verifying compliance with the regulatory framework under the supervision of the Department of the Treasury. In addition, record-keeping obligations will apply for a minimum period of five years.
The measures also expand the definition of “prohibited Cuban government officials.” The new definition includes not only senior executive and legislative officials, but also trade union leaders, Supreme Court judges, as well as executives and editors of state-owned media outlets. This classification entails legal consequences whereby these individuals become subject to commercial, financial, immigration, and socio-political restrictions in their interactions with U.S. entities and citizens, including a prohibition on receiving economic benefits or participating in authorised transactions.
The memorandum also signals the Executive Branch’s intention to promote the development of the private sector in Cuba and to facilitate internet access as purported mechanisms to support civil society. To this end, it foresees a review of U.S.-funded democracy programs and the creation of an interagency task force responsible for identifying technological solutions to enable information flows into Cuba, with implementation to be overseen by the Department of State.
However, despite the rhetoric and apparent firmness of these provisions, their supposed novelty is largely illusory, as they do not substantially alter the existing regulatory framework. In reality, they form part of the historical pattern of unilateral measures adopted by the United States, characterised by their controversial and persistent claim of extraterritorial application.
In this context, it is important to highlight the sustained response of the European Union through Council Regulation (EC) No. 2271/96, known as the Blocking Statute, which establishes a legal framework protecting EU persons and companies from the extraterritorial effects of sanctions imposed by third countries, such as U.S. measures against Cuba.
Accordingly, these provisions should not directly affect or condition commercial or financial operations between European and Cuban economic actors, particularly in the context of business-to-business (B2B) relations, which remain duly protected under applicable EU law.
You may consult all the measures at the following link: https://www.whitehouse.gov/presidential-actions/2025/06/national-security-presidential-memorandum-nspm-5