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Date Released May 7 2026

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1252. Does E.O. 14404 alter U.S. sanctions on Cuba pursuant to the Cuban Assets Control Regulations (CACR)?

No. All existing prohibitions and authorizations pursuant to the CACR remain in effect. E.O. 14404 was issued pursuant to the International Emergency Economic Powers Act (IEEPA), and is distinct from

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1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA?

Generally, yes, but the U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind dow

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