Sanctions Evasion Reference

Cuba sanctions

The oldest US embargo still administered by OFAC: the Cuban Assets Control Regulations of 1963, layered with later statutes, that prohibit most transactions involving Cuba or its nationals unless licensed.

target

Cuba

since

1963

authorities

1 listed below

reviewed

2026-09-20

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 20). Cuba sanctions. https://sanctionsevasion.org/reference/programs/cuba/
Chicago 
Sanctions Evasion Reference. “Cuba sanctions.” Last reviewed September 20, 2026. https://sanctionsevasion.org/reference/programs/cuba/.
BibTeX 
@misc{ser-reference-programs-cuba,
  author = {{Sanctions Evasion Reference}},
  title  = {Cuba sanctions},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/reference/programs/cuba/}
}

The date is when this page was last reviewed, not when it was first published.

Cuba is different from the other programmes here in structure: it prohibits by default and permits by licence, rather than blocking listed persons.

How the prohibition is written

31 CFR 515.201 prohibits, “except as specifically authorized”, transactions by, on behalf of, or at the direction of a designated foreign country or any national of it, and transactions involving property in which that country or a national has at any time had “any interest of any nature whatsoever, direct or indirect”. It names transfers of credit and payments through any banking institution wherever located involving property subject to US jurisdiction, foreign exchange transactions, and the export or withdrawal of gold, silver, currency or securities.

The regulations date from 9 July 1963 (28 FR 6974). Their authority line shows how many layers have been added since: the Trading with the Enemy Act, a 1948 executive order, a 1962 proclamation, a 1993 executive order, and several later statutes. A reader working on a Cuba question is reading a regulation that has been amended for more than sixty years, not one drafted for the present.

Why the structure matters

Because the test is an interest “of any nature whatsoever, direct or indirect”, the analysis is closer to a property-interest question than a list-match. An entity that appears on no list can still be caught if a Cuban national holds an interest in the transaction. That is the opposite of the position under the fifty percent rule, which sets a numerical threshold, and it is why a screening approach built only on names is weakest here.

The page records the legal structure only. The detailed exemptions, general licences and category-specific rules change often and should be read on OFAC’s own Cuba pages, linked from the sources list.

Authorities administering this programme

Legal basis and official pages: Cuban Assets Control Regulations, 31 CFR Part 515.

Techniques that appear here

Sources

  1. Cuban Assets Control Regulations, 31 CFR Part 515. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. 31 CFR Part 515; issued 9 July 1963 (28 FR 6974).
  2. Sanctions Programs and Country Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  3. Frequently Asked Questions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.