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ARTICLE · 18 OCTOBER 2026

OFAC Expands Cuba Sanctions And Updates Iran Sanctions

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The U.S. Treasury's Office of Foreign Assets Control has issued sweeping regulatory changes affecting Cuba and Iran sanctions programs, introducing new restrictions on financial transactions, travel authorizations, and banking activities. These amendments establish separate regulatory frameworks, expand prohibited transaction categories, and consolidate penalty provisions across multiple sanctions programs, creating significant compliance implications for U.S. persons and foreign financial institutions.

CubaInternational Law
Carie Cartwright
Carie Cartwright
Mariana Pendás Fernández
Mariana Pendás Fernández

On September 29, 2026, effective September 30, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a package of regulatory actions reorganizing multiple OFAC regulations, tightening the Cuba sanctions program, and incorporating existing authorities into the Iranian Transactions and Sanctions Regulations (31 C.F.R. Part 560) (“ITSR”). The Cuba measures include the new Cuba Sanctions Regulations (31 C.F.R. Part 516) (“CSR”), amendments to the Cuban Assets Control Regulations (31 C.F.R. Part 515) (“CACR”), new and revised FAQs, and an OFAC Alert.

New Cuba Sanctions Regulations

OFAC issued the CSR to implement Executive Order (“E.O.”) 14404 of May 1, 2026, which established a new Cuba-related sanctions authority by authorizing the blocking of persons determined to operate in specified sectors of the Cuban economy, support the Government of Cuba or designated persons, or engage in other sanctionable conduct, and by authorizing the imposition of

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