The Office of Foreign Assets Control (OFAC) recently announced a broad tightening of U.S. sanctions on Cuba, with new and amended rules that took effect on September 30, 2026. The core of the expansion is Executive Order 14404, signed on May 1, 2026, and carried out through the new Cuba Sanctions Regulations (31 CFR part 516). Under this authority, foreign persons, Cuban or otherwise, can be sanctioned for specified harmful conduct tied to Cuba, and foreign financial institutions risk sanctions of their own if they handle significant transactions for anyone blocked under the order.
OFAC also amended the long-standing Cuban Assets Control Regulations (31 CFR part 515) to roll back several activities that were previously allowed. On travel, U.S. persons may no longer attend or organize professional meetings in Cuba, group people-to-people educational travel has been eliminated, and other educational trips must now be sponsored by a U.S.-jurisdiction organization, with most travelers escorted by a sponsor representative. On banking, the ban on dealing with entities on the Cuba Restricted List now reaches indirect transactions, banks may no longer process so-called “U-Turn” transfers involving Cuban interests, and banks can no longer hold accounts for Cuban independent private sector entrepreneurs, with existing accounts to be blocked and reported to OFAC.
OFAC’s alert, which was issued on September 29, 2026, also highlights several carve-outs and transition measures that soften the impact of the new rules. Through General License 1, issued May 7, 2026, OFAC permits dealings that would otherwise breach the executive order if they were already licensed or exempt under the Cuban Assets Control Regulations, such as certain family remittances and shipments of food, medicine, and medical devices. Travelers and organizers have until October 30, 2026, to wind down certain transactions tied to the now-revoked professional meetings authorization, and educational or people-to-people trips may still go forward if at least one related purchase, such as a flight, was made before September 30, 2026. Accredited U.S. degree-granting institutions, along with their students and full-time permanent staff, are exempt from the escort requirement for certain educational activities. On the banking side, institutions that encounter U-Turn transfers may reject them rather than block them, and they may continue to keep accounts for other Cuban nationals in Cuba to receive payment for authorized or exempt transactions. Anyone whose planned activity is not covered by an existing authorization or exemption may apply to OFAC for a specific license.