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Cuban Assets Control Regulations
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Cuban Assets Control Regulations

US regulatory framework governing permitted economic transactions with Cuba; administered by OFAC since 1963.

The Cuban Assets Control Regulations, in force since 1963, became the base layer of a three-tier US sanctions architecture through 2026, most recently exposed on 13 July when OFAC guided two designated firms through a wind-down but left tourism-sector counterparties with no cover at all.

Last refreshed: 17 July 2026 · Appears in 1 active topic

Key Question

When the new Cuba EO needed a foundation, OFAC reached for a 1963 ruleset; why?

Timeline for Cuban Assets Control Regulations

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Background

The Cuban Assets Control Regulations (CACR) are the primary US regulatory framework governing economic transactions with Cuba, administered by OFAC within the US Treasury Department under the Trading with the Enemy Act and related statutory authorities. They establish the licensing system for the narrow categories of transaction the US permits with Cuba: remittances, travel, agricultural sales under the Trade Sanctions Reform and Export Enhancement Act, and telecommunications.

The CACR date to 1963 and have been amended repeatedly across administrations: President Obama's 2014-2016 normalisation expanded CACR licences for travel, remittances and commercial activity; the first Trump administration reversed much of that expansion; President Biden partially restored it. That back-and-forth history is why the framework remains the reference point every new Cuba sanctions action gets tested against, rather than a settled body of rules.

Three Republican members of Congress from South Florida wrote to Treasury on 11 February 2026 demanding a comprehensive purge of CACR specific licences; Treasury has not published a response.

Key Issues
Sanctions architecture

CACR now anchors three sanctions layers

President Trump's Executive Order 14380, signed 29 January 2026, made the CACR the licensing base for a new secondary-tariff mechanism reaching third-country oil suppliers, well beyond the CACR's traditional US-persons jurisdiction. On 7 May, OFAC formally numbered a further order, Executive Order 14404, and issued Cuba General License 1 as a savings clause aligning the new personal-designations track with the pre-existing CACR framework, without expanding any CACR-authorised transaction category.

By 13 July, the layering showed its gaps: OFAC guided two of ten newly designated firms, GECOMEX and GEMAR, through a 30-day wind-down to 12 August, but issued nothing for the Ministry of Tourism, designated the same day, leaving travel agents and card processors handling live Cuba bookings with no published cover.

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
What is Cuba General License 1?
Cuba GL 1, published by OFAC on 7 May 2026, is a savings clause under newly numbered Executive Order 14404 that aligns the new personal-designations architecture with the pre-existing Cuban Assets Control Regulations. Its text grants no fuel-delivery authority.Source: OFAC Federal Register
How do the CACR work in 2026?
The CACR remain the structural framework licensing permitted Cuba transactions, layered now beneath two newer instruments: EO 14380 (third-country fuel-supply secondary tariffs) and EO 14404 (personal SDN designations under the [Cuba-EO] tag).Source: OFAC / CFR Title 31 Part 515
Who administers Cuba sanctions in the US?
The Office of Foreign Assets Control (OFAC) within the US Treasury Department administers the CACR and issues general and specific licences. Treasury Secretary Scott Bessent authorises significant policy actions including the 7 May 2026 issuance of Cuba GL 1.Source: US Treasury Department
When were the Cuban Assets Control Regulations created?
The CACR date to 1963, implementing the Trading with the Enemy Act and related statutory authorities. They have been amended repeatedly across administrations, most recently with the layered 2026 architecture under EO 14380 and EO 14404.Source: US Federal Register
Why did the new Cuba EO need to align with the old CACR?
Cuba GL 1's savings clause preserves existing CACR-authorised transaction categories under EO 14404 to avoid retroactively criminalising transactions already permitted under OFAC specific or general licences when the new EO was signed on 1 May 2026.Source: OFAC Federal Register / Baker McKenzie Sanctions Blog
What is OFAC FAQ 1262?
FAQ 1262, published on 13 July 2026 alongside that day's Cuba designations, grants GECOMEX and GEMAR a 30-day wind-down to 12 August but issues no equivalent guidance for the Ministry of Tourism (MINTUR), which was designated the same day.Source: OFAC