Cuba's cabinet published a revised Decree 325, the implementing regulation for the 2014 Foreign Investment Law No. 118, as document GOC-2026-495-ES11 in the Gaceta Oficial, Cuba's official state gazette, on 4 September1. It follows Decree-Law 128/2026, approved on 3 September, and the two instruments do different work. The decree-law introduces direct hiring and wider financial autonomy for foreign-capital enterprises, while the decree rewrites the procedure through which foreign investment is submitted, approved, monitored and wound up.
The state employment agency sits on the payment chain. A foreign employer pays the state in hard currency, the state pays the worker a fraction of it in pesos, and the state keeps the spread. Cuba built that arrangement in the 1990s to earn foreign currency from joint ventures, and if Decree 325 is applied as written, a foreign-invested firm may now contract Cuban staff without it. Washington's sanctions authority, OFAC, designated the Comercializadora de Servicios Médicos Cubanos (CSMC), the company that markets Cuban doctors' labour abroad, in July on exactly that reading of the same structure. Washington and Havana are pulling at one mechanism from opposite ends, one by designation and one by decree.
Nothing in the gazette says direct hiring is happening, and no foreign-invested firm has been reported using the new rule. The 176-measure package the National Assembly passed on 18 June authorised private banks and exchange houses, and no licence for either had been issued by 1 July. Decreto 160 took force on 4 August and required implementing provisions within seven days, which did not arrive. Until a ministry publishes a model contract that omits the agency, Decree 325 grants a permission rather than changing anyone's payroll.
The decree still tells a reader where Havana now stands. Writing down a willingness to give up a wage capture the state built to survive the loss of Soviet subsidy says something about what it has left to trade. The Ministry of Foreign Trade and Foreign Investment (MINCEX) oversees implementation2.
