News 19 May, 2026 Cuba Sanctions Alert - Significant New Risks for Non-US Persons Tony Paulson Head of Asia & Corporate Director On 1 May 2026, President Trump signed Executive Order 14404 ("EO"), titled "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy." This marks a significant escalation in the US sanctions framework targeting Cuba and introduces material new risks for non-US persons and entities - including shipowners, operators, charterers, and financial institutions active in Cuba-related trade. Download PDF The EO operates alongside, but separately from, the long-established Cuban Assets Control Regulations (CACR) , which impose a comprehensive embargo on dealings with Cuba by US persons. Crucially, the EO does not replace the CACR - both regimes now operate in parallel. What Has Changed Prior to the EO, the US Cuba sanctions regime was primarily a concern for US persons and their subsidiaries. The new EO changes this materially. For the first time, non-US companies - including foreign shipowners, managers, traders, and financial institutions - face the risk of being designated under US sanctions for certain Cuba-related activities, even where no US nexus exists. The EO authorises the imposition of blocking (asset-freezing) sanctions on foreign persons determined to be: Operating in targeted Cuban economic sectors , specifically: energy; defence and related materiel; metals and mining; financial services; and security. The Secretary of the Treasury may add further sectors at any time. OFAC explains in FAQ 1256 that “it does not automatically impose sanctions on all persons who operate or have operated in those sectors.” Affiliated with the Government of Cuba or sanctioned persons  - including those who have materially assisted, sponsored, or provided financial, material, technological support, goods or services to the Cuban Government or any person blocked under the E