OFAC issued Cuba General Licences 2, 3 and 4 alongside the 23 July designations, authorising a defined set of transactions the blocking action would otherwise have caught1. General Licence 4 permits third-country embassies in Cuba to keep operating, while General Licences 2 and 3 wind down CEIBA Investments Limited, a Guernsey-listed fund invested in Cuban hotels2.
General licences are the release valves in a sanctions regime: they let specified parties exit or continue without breaching the block, so foreign firms and missions are not stranded by a designation aimed elsewhere. The CEIBA wind-down follows the pattern set on 13 July, when OFAC opened a GECOMEX and GEMAR wind-down window, giving counterparties a defined runway rather than an abrupt cut-off.
Managing the exits matters to the campaign's durability. An abrupt block that traps allied embassies or European investors invites diplomatic pushback and legal challenge; a licensed wind-down lets the pressure land on the intended Cuban state target while third parties leave cleanly. The licences are the quiet half of a designation wave whose headline is the medical-missions strike.
