OFAC Warns Foreign Firms on Cuba Military-Links

The Treasury Department’s Office of Foreign Assets Control warned non-U.S. companies and financial institutions that transactions involving Cuba’s military and security apparatus may expose them to U.S. sanctions, extending compliance risk beyond entities formally named on U.S. sanctions lists.

In new Cuba-related FAQ 1258, issued June 4, OFAC said Grupo de Administración Empresarial S.A., the Cuban Ministry of the Interior and the Ministry of the Revolutionary Armed Forces are all blocked under Executive Order 14404. The agency said sanctions risk also extends to any entity that GAESA, MININT or MINFAR owns, directly or indirectly, by 50 percent or more. 

OFAC ties the warning to the State Department’s Cuba Restricted List. OFAC said many CRL-listed entities are majority-owned by GAESA, MININT or MINFAR and therefore present “the same sanctions risk.” It added that even non-blocked CRL entities could be targeted in future sanctions actions, and that persons transacting with any CRL entity “may run the risk of themselves being sanctioned by the U.S. government.” 

The FAQ accompanied new SDN List updates. OFAC added several Cuban individuals, including Miguel Díaz-Canel Bermúdez and Alejandro Castro Espín, and entities including Amistur Cuba SA, the Committees for the Defense of the Revolution, the Cuban Institute of Friendship with the Peoples, Minera La Victoria SA and MINFAR.