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On September 3, 2026, OFAC announced Cuba-related SDN designations and issued Cuba General License 4A, “Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba.” Per the GL text, effective September 3, 2026, GL 4 (dated July 23, 2026) is replaced and superseded in its entirety by GL 4A.

GL 4A authorizes, with stated exceptions, transactions involving persons blocked under E.O. 14404 that are ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in Cuba, and certain related personal-expenditure account activity for mission employees, grantees, and contractors (and family members sharing a common dwelling). It does not authorize the unblocking of blocked property.

SDN additions named on OFAC’s September 3 recent-actions page include: Fidel Ernesto Castro Calis; Banco Exterior de Cuba; Comercial CUPET S.A.; Empresa de Servicios Comandante René Ramos Latour (a.k.a. NICAROTEC); Empresa Importadora de Abastecimiento para el Petróleo (a.k.a. ABAPET), linked to Unión Cuba Petróleo; and Empresa Importadora y Abastecedora del Níquel (a.k.a. CEXNI).

State’s accompanying fact sheet states that Banco Exterior de Cuba was designated for operating in the financial services sector of the Cuban economy; NICAROTEC and CEXNI for the metals and mining sector; ABAPET as owned/controlled by or acting for CUPET; and Comercial CUPET S.A. for operating in the energy sector. Castro Calis is described as designated as an adult family member of Alejandro Castro Espín.

For watchers and SMBs: treat these as SDN List changes under E.O. 14404, verify names on OFAC’s list, and remember the CACR still apply in parallel. This brief is informational only — not legal advice.

On August 20, 2026, OFAC updated the SDN List with Cuba-related designations under E.O. 14404, including the Ministry of Construction of Cuba (a.k.a. MICONS; a.k.a. MINCONS). OFAC also amended Cuba-related FAQ 1265.

State’s August 20 fact sheet describes MICONS as designated as a political subdivision, agency, or instrumentality of the Government of Cuba, and notes additional Cuba-related designations that day (including ICAP leadership individuals and several state-owned enterprises named on the OFAC page).

FAQ 1265 states that the U.S. government does not intend to target foreign persons, including foreign financial institutions, under E.O. 14404 for transactions ordinarily incident and necessary to the wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, through September 19, 2026. It also warns that returning assets to a sanctioned party or transferring them for the target’s potential use can create significant sanctions risk.

FAQ 1265 further clarifies that this limited non-targeting posture does not authorize persons subject to U.S. jurisdiction to engage in CACR-prohibited transactions with MICONS, including in connection with a non-U.S. person’s wind-down, absent OFAC authorization. It points to possible relevant authorizations under CACR subpart E and under E.O. 14404 via GL 1 (see FAQ 1253).

Informational only — not legal advice. Always verify against primary OFAC materials.

On July 23, 2026, OFAC added CEIBA Investments Limited (Guernsey) to the SDN List under E.O. 14404 and issued three Cuba-related general licenses: GL 2 (CEIBA wind-down), GL 3 (certain CEIBA debt/equity/derivative transactions), and GL 4 (third-country official missions in Cuba).

Per GL 2, transactions prohibited by E.O. 14404 that are ordinarily incident and necessary to the wind down of any transaction involving CEIBA Investments Limited, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest, were authorized through 12:01 a.m. eastern daylight time, August 22, 2026, subject to the license’s conditions (including that any payment to a blocked person be made into a blocked interest-bearing account in the United States).

Per GL 3, certain ordinarily incident transactions related to divestment or transfer of covered CEIBA debt or equity to a non-U.S. person, clearing/settling of trades placed before 4:00 p.m. EDT July 23, 2026, and wind-down of specified pre-existing derivative contracts were likewise authorized through 12:01 a.m. EDT August 22, 2026, subject to stated limitations.

GL 4 authorized certain transactions for third-country official missions in Cuba; it was later replaced and superseded by GL 4A on September 3, 2026. OFAC’s July 23 page also lists other Cuba-related SDN additions that day; this brief focuses on CEIBA and the three GLs.

Informational only — not legal advice. Check whether a wind-down window has expired before relying on it.

On July 13, 2026, OFAC updated the SDN List under E.O. 14404 and issued Cuba-related FAQ 1262. Entities added that day include Grupo Empresarial del Comercio Exterior (GECOMEX), Grupo Empresarial de Transporte Marítimo Portuario (a.k.a. GEMAR), and the Ministry of Tourism of Cuba (a.k.a. Ministerio de Turismo de Cuba; a.k.a. MINTUR), among other Cuba-related designations listed on the OFAC page.

FAQ 1262 addresses GECOMEX and GEMAR specifically. It states that the U.S. government does not intend to target non-U.S. persons, including FFIs, under E.O. 14404 for transactions ordinarily incident and necessary to the wind down of transactions involving GECOMEX, GEMAR, or any entity in which either owns, directly or indirectly, a 50 percent or greater interest, through August 12, 2026.

FAQ 1262 also states that persons subject to U.S. jurisdiction have long been prohibited under the CACR from transacting with GECOMEX and GEMAR absent OFAC authorization, and that the limited non-targeting posture does not authorize U.S.-jurisdiction persons to engage in those transactions, including in connection with a non-U.S. person’s wind-down, unless separately authorized. It notes relevant authorizations may include certain CACR humanitarian authorizations and E.O. 14404 GL 1 (see FAQ 1253).

Informational only — not legal advice.

On June 11, 2026, OFAC added Unión Cuba Petróleo (a.k.a. CUPET) to the SDN List under E.O. 14404. The listing identifies CUPET as a state-owned enterprise (Entity Code 2605 (Cuba)).

OFAC’s recent-actions page for that date links a press release titled “Sanctioning Cuba’s State-Owned Oil and Gas Company Unión Cuba-Petróleo.” This brief does not expand beyond what that OFAC page and the SDN entry state.

Subsequent September 3, 2026 designations named additional energy-related entities including ABAPET (linked to CUPET) and Comercial CUPET S.A. Readers tracking energy-sector exposure should verify current SDN entries on OFAC’s list.

Informational only — not legal advice.

On May 7, 2026, the Department of State designated Grupo de Administración Empresarial S.A. (GAESA), Ania Guillermina Lastres Morera (Lastres), and Moa Nickel SA (MNSA) under E.O. 14404. OFAC’s recent-actions page that day records related SDN List updates (including Lastres Morera as an individual addition and updates to GAESA and Moa Nickel SA entries) and the issuance of Cuba General License 1 plus FAQs 1251–1256.

State’s release describes GAESA as designated for operating in the financial services sector of the Cuban economy; Lastres for being a leader/official/senior executive officer or board member of GAESA; and Moa Nickel SA for operating in the metals and mining sector.

GL 1 authorizes all transactions prohibited by E.O. 14404 to the extent such transactions are authorized or exempt under the CACR (31 CFR part 515), including under CACR general or specific licenses. Per FAQ 1253, GL 1 does not expand CACR authorizations; it is intended so CACR-authorized activity is not interrupted when a person blocked under the CACR is also blocked under E.O. 14404.

FAQ 1254 stated a limited non-targeting posture for foreign persons, including FFIs, for ordinary wind-down transactions involving GAESA (or 50%-owned entities) through June 5, 2026, while reiterating that persons subject to U.S. jurisdiction remain prohibited from GAESA transactions under the CACR absent authorization. FAQ 1256 clarifies that identifying economic sectors in E.O. 14404 creates sanctions risk but does not automatically sanction every person operating in those sectors.

Informational only — not legal advice.

On May 1, 2026, the White House issued Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy.” According to OFAC FAQ 1251, the order takes further steps under the national emergency related to Cuba and creates a new Cuba-related sanctions program under the International Emergency Economic Powers Act (IEEPA).

That IEEPA program is separate from, and in addition to, the long-standing Cuban Assets Control Regulations (CACR), 31 CFR part 515. Existing CACR prohibitions and authorizations remain in effect. E.O. 14404 also states that actions under the order do not invalidate licenses issued under the CACR.

In plain English: the United States already had a broad Cuba embargo framework. E.O. 14404 adds another layer that can reach non-Cuban foreign persons for certain Cuba-related support, and it authorizes secondary-sanctions tools against foreign financial institutions that conduct or facilitate significant transactions for persons blocked under the order.

OFAC has emphasized that foreign persons and foreign financial institutions should treat the new program as real sanctions-risk exposure for certain Cuba-related conduct. On May 7, 2026, OFAC issued Cuba-related General License 1, authorizing transactions prohibited by E.O. 14404 where those same transactions are authorized or exempt under the CACR, plus related FAQs.

For small businesses and US–Cuba watchers, the practical takeaway is to monitor official OFAC materials rather than informal summaries, and to assume that compliance analysis may involve both the CACR and this newer IEEPA-based program. This brief is informational only — not legal advice. Always verify against primary Treasury sources and consult qualified counsel before taking action.

U.S. rules on remittances to Cuba and authorized travel categories are set out in the Cuban Assets Control Regulations and related OFAC guidance. Those rules can change, and informal summaries go stale quickly.

For small businesses and US–Cuba watchers, the reliable step is to check the official OFAC Cuba Sanctions page for current program information, FAQs, and licenses before relying on secondary write-ups — including older archive cards on this site.

This item is a source pointer, not a substitute for reading the primary materials. Not legal advice. Consult qualified counsel for any remittance, travel, or commercial question involving Cuba.