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The formal designation of GAESA under the Executive Order 14404 signed by Trump on May 1, 2026, and executed this Thursday by the State Department at the request of Secretary Marco Rubio, turns Cuban tourism into the primary battleground of the financial stranglehold on the Havana regime.
The fact that many foreign analysts underestimate is structural: in Cuba, there is no large-scale civilian tourism sector.
What is referred to as "Cuban tourism" is, in terms of asset ownership, an arm of the military conglomerate GAESA (Grupo de Administración Empresarial S.A.), which controls approximately 110 hotels with about 50,000 rooms through its subsidiary Gaviota S.A., dominating Varadero, the northern keys, northern Holguín, and Trinidad/Cayo Largo.
The expanded definition of "Government of Cuba" in Sec. 7(b) of E.O. 14404 also includes formally civil chains—Cubanacán, Gran Caribe, and Islazul—which means that virtually all of Cuba's hotel inventory is under sanction risk, not just that of Gaviota.
Spain is the country with the highest operational exposure. Meliá Hotels International, managing between 32 and 35 hotels and historically having Cuba represent between 8% and 15% of its EBITDA, now faces a second wave of sanctions in addition to the nearly 6,000 lawsuits under Title III of Helms-Burton, valued at around 8 billion euros.
Meliá has 12 hotels in the U.S., mostly in Florida, while Iberostar has a presence in Miami: losing the correspondent relationship in dollars would be existential for both chains.
The available strategic options really come down to two: a complete exit resulting in hundreds of millions in accounting losses, or a partial exit arguing that some hotels are not direct counterparts of GAESA, an argument that could also be invalidated by the broader definition in the presidential order.
Canada, the leading source market with between 900,000 and 1.1 million annual visitors in good years —accounting for 40% to 45% of the total— faces the collapse of its tourism flow through a different avenue: the cessation of Visa and Mastercard processing at the Gaviota hotel point of sale terminals would undermine the value proposition of the "all-inclusive" package that supports this market.
The Canadian flow has already decreased by 54.2% in the first quarter of 2026, with only 124,794 visitors compared to 272,319 in the same period of 2025, and the projection post-E.O. 14404 indicates an additional drop of between 50% and 70% in 12 months.
The payment system is where sanctions cut first and most effectively: Fincimex —the card and remittance processor controlled by GAESA— has been on the Office of Foreign Assets Control (OFAC) list of blocked entities since 2020, and platforms like Booking, Expedia, and Hotelbeds, all with a presence in the U.S., will have to decide whether to disconnect Gaviota's inventory from their systems.
Cuban tourism was already in free fall before this order: in 2025, only 1.81 million international tourists arrived, 62% below the historic record of 4.7 million reached in 2018, with a hotel occupancy rate of 18.9%, the lowest in decades.
Projections for 2026-2027 estimate a decline in total visitors to between 700,000 and one million, with foreign exchange earnings from tourism plummeting from approximately 1.8 billion dollars to between 400 and 600 million, which directly impacts the more than 300,000 Cuban workers linked to the sector.
Tourism contributes between 10% and 15% of Cuba's GDP and between 25% and 35% of fresh foreign currency not coming from remittances, which turns this stranglehold into a structural liquidity crisis for the regime.
Foreign companies have until June 5, 2026 —thirty days— to complete orderly closure transactions with GAESA or with entities in which the military conglomerate holds 50% or more of the share.
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