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The Central Bank of Cuba published the Resolution 45/2026, a regulation that establishes specific provisions for the prevention of terrorism financing and requires both individuals and legal entities on the island to freeze funds and report suspicious activities under the threat of administrative, criminal, and civil penalties.
The resolution, issued on April 22 and published in the Official Extraordinary Gazette No. 63, applies to all transactions that may pose risks associated with the financing of terrorism, including financial transactions, donations, fund transfers, currency exchange operations, and dealings with virtual assets.
According to Article 3 of the regulation, when any individual or legal entity becomes aware that the funds it receives originate from entities designated by the UN Security Council, it must "refrain from continuing the business or transaction and immediately notify the General Directorate of Financial Operations Investigation of the Central Bank of Cuba, for the purpose of freezing said funds or assets without delay and without prior notification."
The obligation to freeze assets is not limited to those linked to a specific terrorist act but extends to all funds controlled directly or indirectly by designated individuals or entities, including those acting on their behalf.
The regulation explicitly invokes the resolutions of the UN Security Council 1267 (1999), 1373 (2001), 1989 (2011), 2253 (2015), and 2617 (2021), as well as the Recommendations of the Financial Action Task Force (FATF) as the basis for the update.
Resolution 45/2026 is part of a broader regulatory framework that the regime has implemented in recent months.
In April, the Ministry of Finance and Prices issued Resolution 86/2026, which designates self-employed individuals, MIPYMES, and bookkeepers as obligated parties to monitor suspicious activities and retain information for a minimum of five years.
In May, the regime also launched a national training program for officials to implement these regulations, coordinated with local governments.
The geopolitical context in which these measures are being implemented involves intense U.S. pressure on Havana.
Donald Trump reinstated Cuba on the list of State Sponsors of Terrorism on January 20, 2025, reversing Biden's decision from January 14 of that year.
In May 2025, the State Department also reincorporated Cuba into the list of countries that do not fully cooperate with anti-terrorism efforts, under the certification of Secretary of State Marco Rubio, who determined that "the Cuban regime did not fully cooperate with the United States on anti-terrorism matters."
In January 2026, Donald Trump signed Executive Order 14380 declaring a national emergency due to the threat posed by the Cuban regime, and on May 1, he expanded sanctions on officials and collaborators of the regime with a order prohibiting their entry into the United States.
The regime, for its part, claims before the UN to be among the 15 jurisdictions of the global FATF network with the best ratings in preventing money laundering and financing of terrorism, and Cuba does not effectively appear on the FATF gray or black lists according to the available updates.
The resolution of the BCC itself acknowledges that "the evolution of global, regional, and national risks related to terrorist financing, the changes in economic and financial processes, the use of new technologies, and the modification of international standards [...] require the updating and strengthening of current legal provisions," which implies that the regime is seeking to demonstrate compliance with international standards at a time of increasing financial isolation.
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