Presidential Determination 2026-21, published in the Federal Register on 25 August, continued Trading With the Enemy Act authority over Cuba for a further year, to 14 September 20271. The 1917 statute is the legal floor beneath the Cuban Assets Control Regulations, the rulebook OFAC, the US Treasury's sanctions administrator, applies to every Cuban designation, so the annual signature keeps the ground under the whole campaign in place.
The determination is procedural and a president has signed one every year since 1977, which is why it draws no attention. It still sets a date. Nothing in the statute now lapses before September 2027, so no expiry can force a pause in the designation programme within the next twelve months, whichever way policy moves in the meantime.
One authorisation did run out in the same month. The wind-down window OFAC opened on 13 July for Cuba's state foreign-trade group GECOMEX and its state maritime group GEMAR expired on 12 August, so a US person still dealing with either company needs a specific licence rather than the general one. The US Supreme Court ruled in June that Helms-Burton, the 1996 law that codified the embargo and lets Americans sue over property expropriated after 1959, strips Cuban state entities of sovereign immunity. A counterparty that stayed in now faces a blocking framework and an open litigation route at the same time.
