On July 22, 2021, the US Department of the Treasury’s Office of Foreign Assets Control designated one Cuban official and one Cuban entity pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act, targeting those who engage in serious human rights abuses and corruption around the world. OFAC sanctioned the Cuban Minister of Defense, who is also the leader of Cuba’s Ministry of the Revolutionary Armed Forces (MINFAR), and sanctioned the Brigada Especial Nacional Del Ministerio Del Interior (SNB), a special forces unit under the Cuban Ministry of the Interior (MININT), for their efforts to suppress peaceful, pro-democratic protestors in Cuba who were calling for an end to Cuba’s 62-year regime and declining living conditions in the country.
The Cuban Minister of Defense was designated under EO 13818 for being a leader of MINFAR, an entity that was blocked in 2017 under OFAC’s Cuban Assets Control Regulations, 31 CFR part 515 (CACR). The SNB was designated pursuant to EO 13818 for being owned or controlled by the MININT, an entity that was designated by OFAC under the Global Magnitsky program in January of 2021.
As a result of these designations, all property interests that were blocked pursuant to CACR will continue to be blocked. In the case of Global Magnitsky sanctions, all US property is blocked, and transactions with designated persons and entities are generally prohibited. In addition, any entity in the US that is owned fifty percent or more by a sanctioned person is also blocked.