On 1 May 2026 the U.S. issued Executive Order 14404 (the “EO”) which represents a significant increase in sanctions risks for non-US persons. Of particular note, the EO authorises sanctions against any foreign person determined:To be operating, or having operated in identified sectors of the Cuban economy, namely:energy;defense and related materiel;metals and mining;financial services;security;any other sector of the Cuban economy as may be determined by the Secretary of Treasury, in consultation with the Secretary of State.To have materially assisted, sponsored or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba or any person whose property is blocked pursuant to the EO.On 7 May 2026 the U.S. made the following designations under the EO:GRUPO DE ADMINISTRACION EMPRESARIAL S.A. (GAESA) for operating or having operated in the financial services sector of the Cuban economy. ANIA GUILLERMINA LASTRES MORERA (LASTRES), for being or having been a leader, official, senior executive officer, or member of the board of directors of GAESA. MOA NICKEL SA (MNSA) for operating or having operated in the metals and mining sector of the Cuban economy. Also, on 7 May the U.S. Office of Foreign Assets Control published FAQs on the EO, emphasising the risks to foreign persons and foreign financial institutions:“…While the United States has long maintained sanctions on Cuba and Cuban nationals pursuant to the CACR (Cuban Assets Control Regulations), E.O.14404 broadens U.S. sanctions on Cuba to include authorizing sanctions on non-Cuban foreign persons for providing support to Cuba and on foreign financial institutions for conducting or facilitating significant transactions involving persons blocked pursuant to E.O. 14404. Foreign persons, including foreign financial institutions, should be aware of the new sanctions risk for engaging in certain conduct with Cuba as outlined in E.O. 14404”.Members are reminded that cover is not available for any trade that breaches applicable sanctions.