U.S. Tightens Cuba Sanctions
Attorneys Andres Fernandez, Aymee Valdivia, Stephanie Connor, Andrew McAllister, Manny Levitt and Kristen Jimenez co-authored a Latinvex article addressing the U.S. government's expanded sanctions framework targeting Cuba under Executive Order 14404 and its interaction with the long-standing U.S. embargo regime. The article details how the new measures introduce heightened compliance considerations encompassing the potential for secondary sanctions on foreign financial institutions (FFIs) and expanded targeting of entities operating in key sectors of the Cuban economy such as energy and financial services. It also explores how these developments add another layer of complexity to an already intricate regulatory landscape shaped by overlapping statutes, regulations and licensing frameworks. The authors outline the implications for companies with ties to Cuba, noting the importance of carefully assessing transaction risk, understanding applicable authorizations and adapting compliance strategies in response to federal enforcement priorities and national security interests.
The article is based on a Holland & Knight alert published by the authors.