Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy
This Presidential Action, issued under the authority granted by the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act (NEA), builds upon the national emergency declared in Executive Order 14380 concerning the policies and actions of the Government of Cuba.
The order directs the Secretary of State and Secretary of the Treasury to block the property and interests in property of foreign persons determined to be involved in operating within key destabilizing sectors of the Cuban economy, engaging in serious human rights abuses, or corruption.
Furthermore, it suspends the entry of such designated aliens into the United States and authorizes sanctions, including blocking U.S.-held assets, against foreign financial institutions that facilitate transactions for blocked persons.
Arguments For
The action reinforces national security and foreign policy interests by targeting threats emanating from the Government of Cuba, as determined to be unusual and extraordinary.
Sanctioning entities operating in key Cuban sectors (energy, defense, finance) directly pressures the regime by restricting access to the U.S. financial system and assets.
Suspending entry for designated aliens protects U.S. interests by blocking access for those involved in Cuban repression or corruption.
The measure invokes established legal frameworks, including IEEPA and the NEA, ensuring the action is grounded in existing statutory authority for national emergency responses.
Arguments Against
Broad sanctions, especially those targeting broad sectors of the Cuban economy, risk imposing unintended negative consequences on the Cuban general population, rather than solely targeting regime officials.
Restricting travel and freezing assets without prior notice, justified by the risk of instantaneous fund transfers, raises procedural due process concerns for affected individuals and entities with constitutional presence in the U.S.
The expansive definitions for "sanctionable conduct" could potentially sweep in entities or individuals whose primary dealings with Cuba are peripheral or humanitarian, creating compliance complexity for U.S. persons.
Reliance on Executive Order 14380 and sweeping discretionary definitions for designating persons may lead to litigation regarding the scope and necessity of the emergency powers invoked.
By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), section 212(f) of the Immigration and Nationality Act of 1952 (8 U.S.C. 1182(f)), and section 301 of title 3, United States Code, and in order to take further steps with respect to the national emergency declared in Executive Order 14380 of January 29, 2026 (Addressing Threats to the United States by the Government of Cuba), I hereby determine and order:
The President issues this order using constitutional and statutory authority, specifically citing the International Emergency Economic Powers Act (IEEPA), the National Emergencies Act (NEA), and immigration law, to address the national emergency concerning the Government of Cuba, which was originally declared in Executive Order 14380 of January 29, 2026.
Section 1. Policy. The policies, practices, and actions of the Government of Cuba, as described in Executive Order 14380, continue to constitute an unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security and foreign policy of the United States. Not only are these policies, practices, and actions designed to harm the United States, but they are also repugnant to the moral and political values of free and democratic societies.
This section establishes the policy basis for the order, asserting that the Cuba government's actions remain an exceptional threat to U.S. national security and foreign policy, originating substantially outside the U.S. The President further emphasizes that these actions contradict the values of free and democratic societies.
Sec. 2. Sanctionable Conduct. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States persons of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in:
This section institutes a blocking of assets belonging to certain foreign persons if those assets are located in the U.S. or come under the control of U.S. persons.
Blocking means these assets cannot be moved, paid out, exported, or otherwise accessed.
(i) any foreign person determined by the Secretary of State, in consultation with the Secretary of the Treasury; or by the Secretary of the Treasury, in consultation with the Secretary of State:
The power to designate these foreign persons for asset blocking rests with either the Secretary of State or the Secretary of the Treasury, following mandatory consultation with the other Secretary.
(A) to operate in or have operated in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, or any other sector of the Cuban economy, as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;
Designation criteria include operating within specified key sectors of the Cuban economy, such as energy, defense, mining, or finance, although the Treasury Secretary, consulting the State Department, can expand this list to other sectors.
(B) to be owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
A person is sanctionable if they are owned, controlled, directed by, or acting on behalf of the Government of Cuba or any already-blocked person.
(C) to own or control, directly or indirectly, any person whose property or interests in property are blocked pursuant to this order;
This criterion targets individuals or entities that own or control any other person whose assets have already been blocked under this order.
(D) 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 or interests in property are blocked pursuant to this order;
This includes anyone who has provided significant support, including financial or material aid, to the Cuban government or any person already designated under this order.
(E) to be or have been a leader, official, senior executive officer, or member of the board of directors of the Government of Cuba or an entity whose property or interests in property are blocked pursuant to this order;
Leaders, high-ranking officials, senior executives, or board members of the Cuban government or blocked entities are subject to designation.
(F) to be a political subdivision, agency, or instrumentality of the Government of Cuba;
Government subdivisions, agencies, or instrumentalities of Cuba are also subject to these blocking sanctions.
(G) to be responsible for or complicit in, or to have directly or indirectly engaged in or attempted to engage in, serious human rights abuse in Cuba;
Individuals involved in or complicit in serious human rights abuses within Cuba are targeted for sanctions.
(H) to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, corruption related to Cuba, including corruption by, on behalf of, or otherwise related to the Government of Cuba, or a current or former official at any level of the Government of Cuba, such as the misappropriation of public assets, expropriation of private assets for personal gain or political purposes, or bribery; or
This addresses corruption linked to Cuba, including bribery, misuse of public assets, or expropriation of private assets for personal or political gain by Cuban officials, past or present.
(I) to be an adult family member of a person designated pursuant to this order.
Family members who are adults of any person designated under this order are also subject to designation.
(b) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that are issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted prior to the date of this order; except that this subsection shall not apply to activities authorized by, and shall not affect the validity of, any license issued pursuant to part 515 of chapter 31 of the Code of Federal Regulations.
The asset blocking prohibitions function unless statutes or specific regulations, orders, or licenses issued under this order provide an exception.
This overrides prior contracts or permits, except for those already authorized under existing regulations in 31 CFR Part 515.
(c) Except to the extent required by section 203(b) of IEEPA (50 U.S.C. 1702(b)), or provided in regulations, orders, directives, or licenses that are issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted prior to the date of this order:
Except as required by IEEPA section 203(b) or specifically authorized by subsequent regulations, this subsection prohibits certain transactions involving blocked property, overriding any pre-existing contractual agreements or licenses.
(i) any transaction or dealing by United States persons or within the United States in property or interests in property blocked pursuant to this order is prohibited, including but not limited to the making or receiving of any contribution of funds, goods, or services to or for the benefit of those persons whose property or interests in property are blocked pursuant to this order;
United States persons cannot engage in any transaction involving blocked property within the U.S. This explicitly bans contributing funds, goods, or services, directly or indirectly, to the blocked persons.
(ii) any transaction by any United States person or within the United States that evades or avoids, or has the purpose of evading or avoiding, or attempts to violate, any of the prohibitions set forth in this order is prohibited; and
Attempting to evade, avoid, or violate any prohibition established by this order is itself prohibited for all U.S. persons and within the U.S.
(iii) any conspiracy formed to violate any of the prohibitions set forth in this order is prohibited.
Conspiring with others to violate any prohibition established in this order is also forbidden.
(d) I hereby determine that the making of donations of the type specified in section 203(b)(2) of IEEPA (50 U.S.C. 1702(b)(2)) by United States persons to persons determined to be subject to subsection (a) of this section would seriously impair my ability to deal with the national emergency declared in Executive Order 14380, and I hereby prohibit such donations.
The President determines that allowing U.S. persons to make specific types of donations to the designated persons would undermine the effectiveness of the sanctions regime related to the national emergency, and thus prohibits those donations pursuant to IEEPA authority.
(e) For those persons determined to be subject to subsection (a) of this section who might have a constitutional presence in the United States, I find that, because of the ability to transfer funds or assets instantaneously, prior notice to such persons of measures to be taken pursuant to this order would render these measures ineffectual. I therefore determine that, for these measures to be effective in addressing the national emergency declared in Executive Order 14380, there need be no prior notice of a listing or determination made pursuant to subsection (a) of this section.
The order allows the immediate imposition of sanctions without prior notice for designated persons, even those with constitutional ties to the U.S. This waiver of notice is justified because the rapid, instantaneous transfer capability of modern finance would otherwise make the sanctions ineffective.
Sec. 3. Travel. (a) I hereby find the unrestricted immigrant and nonimmigrant entry into the United States of aliens determined to meet one or more of the criteria in section 2(a)(i) of this order would be detrimental to the interests of the United States, and I hereby suspend entry into the United States, as immigrants or nonimmigrants, of such persons, except where the Secretary of State, or the Secretary of State’s designee, determines that the person ‘s entry is in the national interest of the United States. Such persons shall be treated in the same manner as persons covered by section 1 of Proclamation 8693 of July 24, 2011 (Suspension of Entry of Aliens Subject to United Nations Security Council Travel Bans and International Emergency Economic Powers Act Sanctions).
The President finds that it is harmful to U.S. interests to allow aliens meeting the criteria listed in Section 2(a)(i) to enter the U.S. Therefore, entry is suspended for these individuals as immigrants or nonimmigrants, unless the Secretary of State specifically determines their entry serves the national interest.
These individuals are treated the same as those restricted under a previous 2011 proclamation.
Sec. 4. Foreign Financial Institutions. (a) The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized to impose on a foreign financial institution one or more of the sanctions described in subsection (b) of this section upon determining that the foreign financial institution has conducted or facilitated any significant transaction or transactions for or on behalf of any person whose property or interests in property are blocked pursuant to this order.
The Secretary of the Treasury, after consulting with the Secretary of State, gains the authority to impose sanctions on any foreign financial institution.
This designation occurs if the institution conducts or facilitates a significant transaction for any person whose assets are already blocked under this order.
(b) With respect to any foreign financial institution determined to meet the criteria set forth in subsection (a) of this section, the Secretary of the Treasury, in consultation with the Secretary of State, may:
If a foreign financial institution meets the criteria in subsection (a), the Secretary of the Treasury, in consultation with the Secretary of State, has the authority to apply the following sanctions.
(i) prohibit the opening of, or impose strict conditions on the maintenance of, correspondent accounts or payable-through accounts in the United States; and
Sanctions can include banning the establishment of new correspondent or payable-through accounts in the U.S. or imposing strict rules on maintaining existing ones.
(ii) block all property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of such foreign financial institution, and provide that such property and interests in property may not be transferred, paid, exported, withdrawn, or otherwise dealt in. The prohibitions described in this subsection shall include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property or interests in property are blocked pursuant to this subsection; and the receipt of any contribution or provision of funds, goods, or services from any such person.
The Treasury Secretary may block all property belonging to the sanctioned foreign financial institution that is in the U.S. or under U.S. control.
This blocking prevents any transactions involving that property, including prohibiting the institution from sending or receiving any funds, goods, or services to or from any person blocked under this clause.
(c) The sanctions described in subsection (b) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted before the date of this order; except that this subsection shall not apply to activities authorized by, and shall not affect the validity of, any license issued pursuant to part 515 of chapter 31 of the Code of Federal Regulations.
These sanctions are effective immediately and supersede prior contracts or licenses, except where statutory provisions or specific regulations/licenses issued under this order provide relief.
This exclusion does not invalidate licenses already issued under 31 CFR Part 515.
(d) I hereby determine that the making of donations of the types of articles specified in section 203(b)(2) of IEEPA (50 U.S.C. 1702(b)(2)) by, to, or for the benefit of any person whose property or interests in property are blocked pursuant to subsection (b) of this section would seriously impair my ability to deal with the national emergency declared in Executive Order 14380, and I hereby prohibit such donations.
The President determines that allowing donations defined in IEEPA section 203(b)(2) to any person blocked under subsection (b) of this section would seriously compromise handling the national emergency, and consequently prohibits such donations.
Sec. 5. Delegation. Consistent with applicable law, the Secretary of State and the Secretary of the Treasury are directed and authorized to take all actions necessary to implement and effectuate this order — including through temporary suspension or amendment of regulations or through notices in the Federal Register and by adopting rules, regulations, or guidance — and to employ all powers granted to the President, including by IEEPA, as may be necessary to implement this order. The head of each executive department and agency (agency) is authorized to and shall take all appropriate measures within the agency’s authority to implement this order. The head of each agency may, consistent with applicable law, including section 301 of title 3, United States Code, redelegate the authority to take such appropriate measures within the agency.
The Secretaries of State and Treasury are mandated to take all necessary steps to enforce this order, including amending regulations or issuing guidance published in the Federal Register, utilizing all presidential powers granted by IEEPA. Heads of other executive departments and agencies must also take appropriate measures within their authority and may redelegate this implementation authority.
Sec. 6. Reporting Directives. The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized and directed to submit recurring and final reports to the Congress on the national emergency declared in, and authorities exercised by, Executive Order 14380, consistent with section 401 of the NEA (50 U.S.C. 1641) and section 204(c) of IEEPA (50 U.S.C. 1703(c)).
The Secretary of the Treasury, in consultation with the Secretary of State, is directed to provide both regular and final reports to Congress regarding the national emergency declared in Executive Order 14380 and any authorities used to implement it, adhering to reporting mandates in the NEA and IEEPA.
Sec. 7. Definitions. For the purposes of this order:
This section provides clear definitions for key terms used throughout the document to prevent ambiguity in the application of the sanctions.
(a) the term “entity” means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization;
The term 'entity' is defined broadly to include various organizational structures like partnerships, corporations, or associations.
(b) the term “Government of Cuba” means the Government of Cuba, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Cuba, and any person owned, controlled, or acting for or on behalf of, the Government of Cuba;
The 'Government of Cuba' is defined to include its political subdivisions, agencies, the Central Bank, and any person acting for or controlled by the Cuban government.
(c) the term “person” means an individual or entity;
'Person' is defined simply as encompassing either an individual or an entity.
(d) the term “United States person” means any United States citizen, lawful permanent resident, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches of such entities), or any person in the United States; and
'United States person' includes U.S. citizens, permanent residents, and any entity organized under U.S. law, including their foreign branches, or any individual physically present in the U.S.
(e) the term “foreign financial institution” means any foreign entity that is engaged in the business of accepting deposits; making, granting, transferring, holding, or brokering loans or credits; purchasing or selling foreign exchange, securities, futures, or options; or procuring purchasers and sellers thereof, as principal or agent. It includes but is not limited to depository institutions; banks; savings banks; money services businesses; operators of credit card systems; trust companies; insurance companies; securities brokers and dealers; futures and options brokers and dealers; forward contract and foreign exchange merchants; securities and commodities exchanges; clearing corporations; investment companies; employee benefit plans; dealers in precious metals, stones, or jewels; and holding companies, affiliates, or subsidiaries of any of the foregoing. The term does not include the international financial institutions identified in 22 U.S.C. 262r(c)(2), the International Fund for Agricultural Development, the North American Development Bank, or any other international financial institution so notified by the Office of Foreign Assets Control.
'Foreign financial institution' is broadly defined, covering entities involved in deposits, lending, securities, or foreign exchange trading.
This includes banks, brokers, and insurance companies, but specifically excludes certain multilateral international development banks.
Sec. 8. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:
This section outlines general provisions clarifying the order's scope and limitations regarding existing authorities.
(i) the authority granted by law to an executive department or agency, or the head thereof; or
The order does not cancel or limit the existing legal authority of executive departments, agencies, or their leaders.
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
The order does not affect the authority of the Director of the Office of Management and Budget concerning budgeting, administration, or legislative recommendations.
(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
Implementation of this order must align with existing law and is contingent upon the availability of necessary funding.
(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
This order is explicitly not meant to create any new enforceable legal rights or benefits for any party against the U.S. government or its personnel.
(d) The costs for publication of this order shall be borne by the Department of State.
The Department of State is responsible for covering the expenses associated with publishing this Presidential Action.
DONALD J. TRUMP
THE WHITE HOUSE,
May 1, 2026.
This documents the signature of President Donald J. Trump and the date of issuance: May 1, 2026.
This is standard footer metadata indicating the title of the post and its original source on the White House website.
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