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When Jeremy Lewin stated that “the regime must return these resources to the Cuban people”, the statement seemed to open an unusual door in the discourse about Cuba: the possibility of a future international recovery of assets associated with GAESA and the military elite of the regime.
Although the scenario outlined by the Undersecretary of State for Foreign Assistance, Humanitarian Affairs, and Religious Freedom—and one of the main advisors of Secretary Marco Rubio—still belongs to the hypothetical realm, it would not be a new phenomenon in international politics.
Over the past few decades, governments, multilateral organizations, and judicial systems have developed specific mechanisms to track, freeze, and eventually recover fortunes linked to authoritarian regimes, state corruption, or money laundering networks.
International experience shows, however, that these processes are often much more complex than they seem.
The first step typically involves identifying and isolating assets. This includes bank accounts, shell companies, real estate, investment funds, and corporate holdings distributed across multiple jurisdictions.
This requires international financial cooperation, access to banking intelligence, and legal frameworks that allow for the justification of precautionary measures.
One of the most important instruments created in recent decades comes into play here: the Stolen Asset Recovery Initiative (StAR), driven by the World Bank and the United Nations Office on Drugs and Crime (UNODC).
The program was specifically designed to help track wealth illicitly extracted from countries through corruption or abuse of power.
The United Nations Convention against Corruption also establishes principles of international cooperation aimed at facilitating the recovery of public assets diverted abroad.
However, one thing is to freeze funds, and quite another is to ensure that they effectively return to the country of origin.
The case of Libya illustrates this difficulty well. After the fall of Muammar Gaddafi in 2011, the UN Security Council froze over 34 billion dollars associated with the Libyan regime. A significant portion of those assets remained immobilized in foreign banks for years as various political factions laid claim to legitimacy over them.
The international community then discovered a recurring issue: when a regime falls, there is not always immediate consensus on who legally represents the State.
Iraq provides another precedent that is even more relevant for the Cuban case. After the 2003 invasion and the fall of Saddam Hussein, the United States and international organizations promoted the Iraq Development Fund, which managed oil revenues and recovered assets to finance institutional reconstruction, public salaries, and basic operations of the new state apparatus.
This precedent is particularly interesting because it directly connects with the discussion beginning to emerge around GAESA: the idea of using recovered assets not only as a political punishment but also as a financial tool to support a transition.
More than Iraq or Libya, the closest precedent for Cuba may be currently unfolding in Venezuela, where frozen assets, oil revenues, and external resources began to be managed through hybrid schemes of international oversight and conditional financial control.
The Venezuelan experience demonstrates that modern sanctions are no longer solely aimed at punishing governments, but also at .
Eastern Europe also offered important lessons. Following the fall of Nicolae Ceaușescu in Romania and the collapse of other communist regimes, numerous governments attempted to track down hidden funds and properties controlled by the former elites.
However, in the post-communist European context, the results were uneven. In many cases, a significant portion of the assets disappeared before legal recovery mechanisms could be activated.
The experience revealed another central issue: dictatorships rarely concentrate their assets under easily identifiable names. They utilize business networks, front men, tax havens, and complex financial structures designed precisely to hinder tracking.
Therefore, the current offensive against GAESA seems to pay particular attention to foreign financial entities and international operators. The U.S. strategy would not be limited solely to applying pressure on the Cuban military conglomerate, but also to dissuading any collaboration with its global financial structures.
Secondary sanctions play a key role in that framework. They act as a mechanism of indirect coercion: they force banks, shipping companies, and foreign businesses to choose between maintaining relations with sanctioned entities or preserving access to the U.S. financial system.
In recent years, that tool has become one of Washington's most powerful instruments for isolating state actors deemed hostile.
But even if assets linked to GAESA could be identified and frozen, enormous legal and political obstacles would arise.
Under what legal framework could they be confiscated? Who would administer those resources? Which government would be internationally recognized as the legitimate recipient? How would it be ensured that the funds do not get captured again by networks of corruption?
Recent history shows that there are no simple answers.
In some countries, the recovered assets were partially used for institutional reconstruction. In others, they ended up stuck for years in international litigation. There are also cases where the dispute over control of those funds exacerbated internal conflicts and power struggles.
Precisely for this reason, Lewin's phrase gains such political relevance. It introduces a logic that transcends conventional sanctions and approaches the realm of state transitions: the idea that the wealth accumulated by a power structure could become the subject of national restitution.
The major question would no longer be just whether there are sufficient assets abroad, but what would happen to them in the event of a political change in Cuba.
And that question inevitably leads to an even more sensitive one: if those resources were to be recovered someday, how could they be used to finance the "day after"?
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