On May 1, 2026, the US issued a new Executive Order that significantly expands the reach of Cuba-related sanctions. Foreign companies and financial institutions may now face exposure based solely on their commercial dealings with certain sectors of the Cuban economy or with Cuban state-linked entities — even without a US nexus.
The new framework closely resembles the sanctions models used against Iran and Russia, raising immediate compliance questions for a wide swath of foreign persons engaging in economic activities involving Cuba. Longstanding assumptions about the scope of Cuba sanctions may no longer apply.
We recently published an update examining what has changed, which sectors are most at risk and what companies should be watching as enforcement begins to take shape.
Read the full insight here.