OFAC, the sanctions arm of the US Treasury, blocked Cuba's Ministry of Construction on 20 August, a government department rather than a company beneath one, together with the Empresa de Níquel Comandante Ernesto Che Guevara, the island's nickel-mining monopoly, the steel trader ACINOX Comercial, the wholesaler CORATUR, and three officials of the Instituto Cubano de Amistad con los Pueblos, the state body that runs Cuba's relations with foreign friendship associations1.
Cuba's construction ministry writes the permits, holds the contracts and owns the enterprises that do the building. A foreign firm on a Cuban site therefore now finds a blocked counterparty at the top of whatever chain it is working in, whether or not the company it signed with was named. The nickel producer appears in the same notice for a different reason. It holds a monopoly on mining the island's nickel, so a designation there reaches export earnings rather than the building programme.
OFAC's Cuban list had until then been built mostly from banks and holding structures, including Banco Financiero Internacional and four firms tied to the military conglomerate GAESA on 23 June. Designations of that kind close payment routes. The 20 August notice does something harder to route around, because it attaches to the department that authorises the work and to the monopoly that mines the ore, neither of which can be replaced by opening an account somewhere else.
