cuba-sanctions 13 February 2025

US State Department republishes Cuba restricted list following policy reversal

The US Department of State has reissued its Cuba Restricted List of entities and subentities with which direct financial transactions are generally prohibited, after reversing the Biden Administration’s suspension of stringent sanctions against Havana, according to a 6 February notice in the Federal Register.

The list identifies entities ‘under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel,’ the department explained. Direct financial transactions with these entities would ‘disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba.’

The reinstated List was rescinded on 16 January following the issuance of National Security Memorandum 29 (‘NSM-29’) by Biden, but was reinstated on 20 January immediately after President Donald Trump entered the White House and issued an Executive Order rescinding NSM. The Department explained, ‘The Secretary of State is therefore re-publishing the Cuba Restricted List.’

The updated list includes one additional subentity not present prior to its rescission in January, according to the notice, which added that the State Department ‘will continue to update the Cuba Restricted List periodically.’

The Bureau of Industry and Security (‘BIS’) ‘will generally deny applications to export or reexport items for use by entities or subentities on the Cuba Restricted List,’ according to the notice.

https://www.federalregister.gov/documents/2025/02/06/2025-02282/publishing-the-state-departments-l ist-of-entities-and-subentities-associated-with-cuba-cuba