On Tuesday 23 June the US Office of Foreign Assets Control (OFAC), the US Treasury's sanctions arm, designated Banco Financiero Internacional (BFI), the state bank that clears the bulk of Cuba's foreign-currency transactions, under Executive Order 144041. Five days earlier, on 18 June, Cuba's National Assembly had legalised private banks and personal dollar accounts. Havana built a front door for private dollars; Washington sanctioned the one clearing bank those dollars must pass through.
OFAC named four other targets alongside the bank: RAFIN S.A., the finance arm of the military conglomerate GAESA; the cargo handler Almacenes Universales S.A.; the mining firm Geominera S.A.; and Annalie Lilliam Rueda Cardero, an adult relative of Alejandro Castro Espín, Raúl Castro's son and former intelligence chief2. Her listing extends to a second Castro-line relative the adult-family-member track OFAC opened when it sanctioned Díaz-Canel and his household on 4 June.
A private-banking law needs a correspondent route to move hard currency abroad, and the designation removes the state bank that supplied it. Treasury and the courts run on separate timetables, and nothing in the record shows the two June moves were synchronised. The narrower, verifiable point holds regardless of intent: any bank licensed under the reform still has to clear dollars through a counterparty willing to touch them, and BFI on the SDN (Specially Designated Nationals) list makes that route unlawful for compliant institutions. The reform this dispatch reported a fortnight ago now lacks the clearing path to work.
