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

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.

How the World Sees Them

Havana

Cuban officials read the layered architecture as a tightening: every existing CACR restriction remains and a new personal-designations layer has been added on top.

Washington

OFAC frames Cuba GL 1 as a routine alignment instrument under EO 14404, not a substantive expansion of permitted Cuba transactions.

US businesses

Hold CACR licences for telecommunications, agriculture, and humanitarian categories; a licence purge would sever all formal channels.

Florida delegation

Republicans demanded comprehensive revocation of CACR specific licences; Treasury has not responded in 96 days but EO 14404 supplies a parallel enforcement track.