Common Questions

What are the Cuban Assets Control Regulations?

The CACR are the US regulatory framework administered by OFAC that govern all economic transactions with Cuba, establishing which activities require licences and which are prohibited. They have been in place since 1963.

How did EO 14380 change Cuba sanctions beyond the existing CACR?

EO 14380 added a secondary tariff mechanism targeting third-country fuel suppliers, extending US sanctions jurisdiction beyond the CACR's traditional scope covering US persons and companies.Source: US Treasury / White House

Can US companies still do business in Cuba in 2026?

Yes, in limited categories. CACR general and specific licences permit remittances, some agricultural sales, and telecommunications. Florida Republicans demanded in February 2026 that OFAC revoke all specific licences with Cuban state entities.Source: Congressional letter / OFAC

Background

The Cuban Assets Control Regulations (CACR) are the primary US regulatory framework governing economic transactions with Cuba, administered by OFAC (Office of Foreign Assets Control) within the US Treasury Department. The CACR implement the Trading with the Enemy Act and related statutory authorities, establishing a licencing system for the limited categories of transactions permitted with Cuba — including remittances, travel, agricultural sales under the Trade Sanctions Reform and Export Enhancement Act (TSRA), and telecommunications. In 2026, the CACR are the regulatory vehicle through which EO 14380's secondary sanctions provisions are operationalised, and the framework against which Florida Republicans demanded a full licence purge in February 2026.

The CACR date to 1963 and have been amended repeatedly across administrations. President Obama's 2014-2016 normalisation process expanded CACR licences for travel, remittances, and commercial activity; the Trump first administration reversed many of those expansions; President Biden partially restored them. The Trump second administration's EO 14380 represents a further tightening, both through the CACR licencing architecture and through the new secondary tariff mechanism that extends beyond CACR's traditional jurisdiction to third countries.

The CACR became the structural anchor for a new layered architecture on 7 May 2026, when OFAC published Cuba General License 1 as a savings clause aligning the newly numbered Executive Order 14404 (1 May, personal designations) with the pre-existing CACR. Cuba GL 1's text grants no fuel-delivery authority; it preserves CACR-authorised transaction categories under the new EO without expanding them. Cuba sanctions now operate on three layered planes: the CACR (long-standing transaction licensing), EO 14380 (third-country secondary tariffs on fuel suppliers), and EO 14404 (personal SDN designations). For US persons and companies, the CACR remains the legal boundary defining permitted Cuba-related activity; the EO 14404 personal-designations track adds a parallel prohibition surface against any transaction involving newly designated [Cuba-EO] individuals such as Ania Guillermina Lastres Morera (7 May 2026). The Giménez-led February 2026 demand targeted the specific-licence category, seeking to close formal commercial channels currently operating under OFAC approval; Treasury has not responded in 96 days.