Cuba Restricted List
US State Department list of entities tied to Cuba's military and security services.
Since 30 September 2026, the Cuba Restricted List has reached indirect transfers when a listed body originates or ultimately benefits from the payment.
Last refreshed: 22 October 2026 · Appears in 1 active topic
How far does the new indirect-dealing ban reach into ordinary Cuba payments?
Timeline for Cuba Restricted List
Background
The Cuba Restricted List is maintained by the US State Department. It names Cuban entities and subentities that the Secretary of State determines are controlled by, act for or benefit the country's military, intelligence or security services. Section 515.209 of the Cuban Assets Control Regulations gives the list its transaction effect.
An OFAC amendment effective on 30 September 2026 expanded the prohibition beyond direct dealings. A payment can now be barred when a listed entity is the originator or ultimate beneficiary, even if an unlisted intermediary handles it. The rule also added an anti-evasion prohibition. That change makes the list more than a name screen: banks and other regulated parties must consider who starts and ultimately receives a Cuba-linked transfer.
Reference
Who decides which entities go on the Cuba Restricted List?
What is the Cuba Restricted List?
How did the 2026 rule change Cuba Restricted List transactions?
Why can an unlisted middleman still create Cuba sanctions risk?
Written with AI from Lowdown's published reporting. Not individually reviewed by an editor. Updated 22 October 2026. Editorial standards.