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Global Trade & Sanctions LawPublished on:
New Cuba Executive Order Creates an IEEPA-Based Sanctions Program and Secondary Sanctions Risk
On May 1, 2026, President Trump issued Executive Order (EO) 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” authorizing sanctions against persons determined to be operating in a variety of sectors of the Cuban economy, with significant impacts to non-U.S. financial institutions who process related transactions. In practical terms, the order gives the U.S. government a new designation authority for foreign persons connected to specified Cuba-related activity and creates a secondary sanctions risk for foreign financial institutions that facilitate significant transactions involving persons blocked under the order.
