Related videos:
The Cuban regime published this Wednesday in the Official Gazette No. 37 Resolution 86/2026 from the Ministry of Finance and Prices, which designates self-employed workers, MIPYMES, non-agricultural cooperatives, and local development projects as financial watchdogs for the State, requiring them to verify whether their clients appear on terrorism lists and to report them secretly to the authorities.
The regulation, signed on April 8 by Minister Vladimir Regueiro Ale, designates all non-state economic actors engaged in bookkeeping activities as "obligated subjects," meaning those who maintain accounts for private businesses.
Article four of the resolution states that these individuals "are responsible for not providing services to clients that are on international lists or on the National List of individuals and entities linked to terrorist actions."
When a match is detected, they must issue a "without delay" Suspicious Transaction Report (STR) to the General Directorate of Financial Operations Investigation (DGIOF) of the Central Bank of Cuba, without informing the investigated client under any circumstances.
The obligation of confidentiality is absolute: private parties "may not disclose the information contained in the ROS, except at the request of a competent authority," according to Article 14.
Additionally, they must retain all relevant customer data for five years after the conclusion of the contractual relationship and must cooperate with the authorities when required.
The failure to comply with these obligations may escalate to the Attorney General's Office, the Ministry of the Interior, and the General Comptroller's Office, according to Article 16 of the resolution.
The measure significantly expands state control over the Cuban private sector amid the crisis, which has more than 11,000 MSMEs registered, generates 31.2% of employment, and contributes 23% of fiscal revenues.
The regulation comes after an unprecedented escalation of regulations: Resolution 56/2024 revoked wholesale trade licenses for TCP, MIPYMES, and cooperatives; the Decree-Law 91/2024 imposed fines of up to 72,000 pesos for violations; and in 2026, mandatory electronic invoicing and restrictions on the use of foreign currency in trade were introduced.
The most revealing element of the regulation is the list that private entities must consult before offering any service: the National Terrorist List of the Cuban regime, updated in July 2025 through Resolution 13/2025 from the Ministry of the Interior, includes 62 individuals and 20 entities, mostly Cuban exiles in Florida.
Among those included are the communicator Alex Otaola, the activist Eliecer Ávila, the Paparazzi Cubano, and organizations such as Alpha-66 and the Cuban American National Foundation, personalities from Miami that the regime labels as terrorists since it published the first version of that list in December 2023.
The government justifies the measure as part of Objective No. 8 of its Social Economic Program—“to advance in the implementation of the general directives aimed at the prevention and reduction of crime, corruption, illegal activities, and social indiscipline”—and as a response to commitments with the Financial Action Task Force of Latin America (GAFILAT), an organization that detected that the non-state sector in Cuba was not integrated into the suspicious transaction reporting system.
In practice, Resolution 86/2026 not only imposes an additional bureaucratic burden on entrepreneurs who are already operating under conditions of extreme crisis: it turns them into extensions of the state control apparatus, forcing them to monitor their own customers and report them in secret to the same authorities that pursue them.
Filed under: