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The United States Department of State has published an updated list of Restricted Entities and Subentities Associated with Cuba, with which direct financial transactions are prohibited under the Cuban Asset Control Regulations (CACR).
The update includes new entities linked to the military and security apparatus of the Cuban regime, reinforcing the restrictions imposed by the U.S. government.
The measure is part of the sanctions policy established in the Presidential Memorandum on National Security 5 (NSPM-5), which instructs the Department of State to identify entities and subentities under the control or acting on behalf of the Cuban military, intelligence, or security services.
As a result, the Bureau of Industry and Security (BIS) of the Department of Commerce indicated that it will deny, in most cases, export or reexport license applications for products intended for the entities included on the list.
Context of the measure
Since the implementation of NSPM-5 in 2017, the U.S. administration has maintained restrictions on financial activities with Cuban state-owned enterprises linked to the Armed Forces and the Ministry of Interior.
However, in January 2025, the list of restricted entities was temporarily removed following the issuance of National Security Memorandum 29 (NSM-29).
However, on January 20, 2025, the current president of the U.S., Donald Trump revoked that decision through an executive order, restoring the Restricted Entities List of Cuba under the guidelines of NSPM-5.
New restrictions under the Helms-Burton Act
The restoration of the Restricted Entities List for Cuba adds to the recent reactivation of Title III of the Helms-Burton Act by the U.S. government.
This provision allows U.S. citizens to sue foreign companies in U.S. courts that conduct business with properties in Cuba that were seized after the revolution.
The measure further tightens the economic blockade against the Cuban regime, complicating foreign investment on the island and increasing pressure on the Cuban government to implement political and economic reforms.
Pressure from the U.S. Congress.
Since the end of 2023, Senator Marco Rubio has been one of the main proponents of updating the List of Restricted Entities of Cuba.
Rubio argued that the Biden administration should include more companies controlled by the Cuban regime, particularly those related to the financial and tourism sectors, which continue to benefit the island's military and intelligence structures.
The recent expansion of the list responds to demands from the political sector advocating for a tougher policy against the totalitarian Cuban regime, and gains even more significance with the appointment of Rubio as Secretary of State in the Trump administration.
Impact on Remittances and the Cuban Financial Sector
One of the entities recently added to the list is Orbit S.A., a company involved in the management of remittances in Cuba.
Its inclusion could significantly affect the transfer of money from the United States to the island, as it prevents U.S. companies from conducting transactions with it.
This adds to the previous restrictions imposed on Fincimex and other entities related to the receipt of remittances in Cuba, further complicating the options for Cubans to receive money from relatives abroad.
Affected entities
Among the main Cuban entities and subentities included in the updated list are:
- Ministries: Ministry of the Armed Revolutionary Forces (MINFAR) and Ministry of the Interior (MININT).
- Corporations and business groups: GAESA (Business Administration Group S.A.), CIMEX, Gaviota, and the Military Industry Union.
- Hotels: Gran Hotel Manzana Kempinski, Iberostar Grand Packard, Meliá Marina Varadero, and several tourist establishments in Havana, Varadero, Santiago de Cuba, Holguín, and the keys.
- Travel agencies and marinas: Crucero del Sol, Excursiones Gaviota, Marina Gaviota Varadero, among others.
- Security and telecommunications companies: SEPSA (Specialized Protection Services S.A.), XETID (Information Technology Company for Defense), and Datys.
- Financial entities: Banco Financiero Internacional S.A. (BFI), Fincimex, RAFIN S.A., Orbit S.A.
The inclusion of these entities on the list means that direct financial transactions with them are prohibited, and any export or re-export of goods to these companies will be denied by U.S. authorities.
Implications for the Cuban private sector
The State Department justified the measure by stating that transactions with these entities disproportionately benefit the Cuban military and security forces, to the detriment of the Cuban people and the emerging private sector on the island.
The U.S. administration claims that the policy aims to prevent the revenues generated by these state-owned companies from being used to maintain the repressive apparatus of the Cuban government.
Availability of the complete list
The updated list of Restricted Entities of Cuba is available on the website of the U.S. Department of State.
For more information, the Department of State has made available the contact for the Office of the Coordinator for Cuban Affairs: Robert Haas, phone: 771-204-7384, email: HaasRZ@state.gov.
This update reinforces Washington's pressure policy on the Cuban government, in a context of bilateral tensions and trade restrictions that continue to affect the island's economy.
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