22OCT

Treasury blacklists a second Cuban bank

2 min read

17:12UTC

OFAC put Banco Internacional de Comercio on its SDN list on 15 October, six weeks after Banco Exterior de Cuba.

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PoliticsAssessed

Key takeaway

Washington has blacklisted two Cuban state banks in six weeks.

OFAC added Banco Internacional de Comercio S.A., a Havana state bank founded in 1993, to the Specially Designated Nationals (SDN) list on 15 October⁠¹. The SDN list is Treasury's blacklist: a listed party's US-reachable assets are frozen, and US persons, and banks clearing through the US, may not deal with it. The Cuban bank arrived as a single line inside a notice otherwise made up of Iran-related designations.

Washington had designated Banco Exterior de Cuba, the trade-finance bank, on 3 September, so the 15 October listing makes it two Cuban state banks in six weeks. Treasury's 2026 campaign started with ministries such as Construction and the operator of Cuba's medical missions. It now reaches the payment system itself, a fortnight after OFAC closed the U-turn route that third-country dollar payments used.

Deep Analysis

In plain English

Banco Internacional de Comercio, known as BICSA, is a Cuban state-owned bank in Havana. It helps Cuban companies pay foreign suppliers and receive money from abroad. On 15 October the US Treasury put it on its main blacklist, the Specially Designated Nationals list. Anything it owns that US law can reach is frozen. American people and banks may not do business with it. Many foreign banks also avoid anyone on that list, because they fear losing access to the US financial system. It is the second Cuban state bank blacklisted since early September.

Deep Analysis

Root Causes

Cuba runs foreign trade through a handful of state banks, not a broad commercial sector. Each one carries the correspondent accounts, letters of credit and SWIFT links for a slice of the island's imports, so a single listing removes a share of the country's payment capacity at once.

The legal basis also explains the pace. Designations under EO 14404 need no new law and no court finding; Treasury publishes a notice and the listing takes effect the same day. That is how one Cuban line could ride inside an Iran-related batch on 15 October.

The campaign has moved down the chain from ministries and medical missions to the banks that settle the island's trade.

What could happen next?

Consequence
Cuban importers must move letters of credit from BICSA to other state banks, adding delay to food and fuel purchases.
Risk
European banks still serving Cuba may close Cuban accounts entirely rather than screen each state counterparty.

Source Landscape

This story draws on neutral-leaning sources

Primary parallel: In September 2005 the US Treasury named Macau's Banco Delta Asia a primary money-laundering concern over North Korean accounts. Macau froze about $25 million, and banks across Asia cut ties with Pyongyang within weeks, because no bank wanted to be the next one named.

Counter-parallel: In July 2012 the US designated China's Bank of Kunlun for handling Iranian payments. Kunlun had no US business to lose, so it kept serving Iran as a dedicated channel, showing that a listing isolates a bank without closing the route when a state lender with no US exposure takes it over.

Immediate effect: BICSA's assets within US reach are frozen, and any payment that names it is likely to stop in screening at foreign banks too. Importers who used BICSA for letters of credit must move them to another Cuban bank, which adds days and fees.

Structural effect: two state banks listed in six weeks narrows the set of Cuban counterparties a cautious European bank will touch. Fewer channels mean slower payment for fuel and food imports, at a time when the informal dollar has already climbed. The listing does not by itself prove any link to the peso's fall; the timing overlaps.

Consensus view: Analysts at the Foundation for Defense of Democracies' Center on Economic and Financial Power favour bank-by-bank designation because each listing feeds straight into compliance software. BICSA's SDN entry carries its SWIFT code, BIDCCUHH, so any bank screening payment messages anywhere will flag a transfer that names it, whether or not dollars are involved.

Counter-view: Researchers at Spain's Real Instituto Elcano have pointed out that the costs of such listings land on European firms, because Spanish hotel groups and traders hold most foreign commercial exposure to Cuba. A Spanish bank facing a Cuban state counterparty on the SDN list tends to close the whole Cuba book rather than defend one client to its US correspondent.

Key tension: Whether Havana can concentrate its foreign trade in one or two unlisted banks fast enough, or whether each new listing pushes more European banks out altogether.

Sources:OFAC / US Treasury·OFAC / US Treasury

Mentions:OFAC →Specially Designated Nationals (SDN) →Banco Exterior de Cuba →Havana →Iran →Foundation for Defense of Democracies →Washington →China →US Treasury →Spain →Cuba →Banco Internacional de Comercio S.A. →

First Reported In

Update #15 · Cuba opens oilfields, US cuts dollar routes

OFAC / US Treasury· 22 Oct 2026

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Causes and effects

Caused by

OFAC hits Cuba's trade bank and traders

OFAC's 3 September designation of Banco Exterior de Cuba preceded the second state bank designation on 15 October.

Occurred 3 Sept 2026

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OFAC closes Cuban firms' US accounts

The 15 October bank designation followed the 30 September rules that closed U-turn and private-sector dollar routes.

Occurred 30 Sept 2026

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This Event

Treasury blacklists a second Cuban bank

Two Cuban state banks now sit on Treasury's blacklist, narrowing the channels left for paying Cuban entities.

Different Perspectives

UN General Assembly

The Assembly passed last year's resolution against the US embargo by 165 votes to 7, with 12 abstentions, and votes again on 28 October. That count is the baseline against which Havana's lobbying claims and Washington's pressure will be measured.

Mexican Navy (Secretaría de Marina)

A Mexican Navy team inspected Grace at Progreso and found fuel in its ballast tanks, according to the US Coast Guard. The account of Mexico's role comes from Washington; the Mexican government's own position on the stop is not on record in the sources reviewed.

Pedro Monreal, independent Cuban economist

Monreal says the gazette contains no rule for the exchange-house licence ADT 64 received, so nobody knows how a second firm could apply. He says a representative rate would need at least ten houses in five provinces, Havana included.

Prisoners Defenders and OCDH (Madrid-based exile monitors)

Prisoners Defenders counted a record 1,351 political prisoners at the end of September, and OCDH logged at least 344 repressive actions that month. OCDH asked the European Union on 11 September to investigate possible trafficking in Cuba's medical brigade in Italy.

Florida Attorney General James Uthmeier

Uthmeier announced a no-bond state warrant for Raúl Castro on 19 October over the 1996 Brothers to the Rescue shootdown, after reopening the state investigation last year. The four men killed flew for a Miami exile group, and the warrant restricts Castro's travel rather than reaching him in Cuba.

Cuban government (Foreign Minister Bruno Rodríguez Parrilla)

Rodríguez said on 21 October that Washington is pressing governments to abstain or leave the hall in the 28 October UN vote and called Florida's Raúl Castro warrant worthless. Havana is presenting its October oil and trade rules as openings and the US measures as an energy blockade.

Written with AI from Lowdown's published reporting. Not individually reviewed by an editor. Editorial standards.