Cuba, Sanctions, and Sovereignty: A Historical Analysis of the 2026 Executive Order
In the long and turbulent history of relations between the United States and Cuba, few episodes have demonstrated the persistence of ideological confrontation as sharply as the executive order issued on May 1, 2026, titled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.” Signed by President Donald J. Trump at the White House in Washington, D.C., the order represented a significant escalation in the economic and diplomatic campaign directed against the Government of Cuba, while simultaneously reviving themes that had shaped bilateral relations since the triumph of the Cuban Revolution in January 1959. Rooted in powers granted under the International Emergency Economic Powers Act (IEEPA), the National Emergencies Act (NEA), and the Immigration and Nationality Act of 1952, the order sought not merely to punish individual officials or institutions but to construct a comprehensive legal architecture aimed at isolating sectors of the Cuban state from global finance, travel, and commerce.
The executive order explicitly referred to Executive Order 14380, issued on January 29, 2026, which had declared that the conduct of the Cuban government constituted an “unusual and extraordinary threat” to the national security and foreign policy interests of the United States. Such language echoed earlier American declarations concerning hostile states during the Cold War, particularly the sanctions regimes imposed against Iran, North Korea, and the former Soviet Union. Yet the 2026 directive also carried unmistakable historical resonance with the longstanding American embargo against Cuba first formalized under President John F. Kennedy on February 7, 1962. That embargo emerged after the nationalization of American-owned property in Cuba and the alignment of Fidel Castro’s government with the Soviet bloc, developments that transformed the Caribbean island into one of the central geopolitical flashpoints of the twentieth century.
By invoking the authorities of IEEPA and the NEA, the order placed Cuba within a framework of emergency economic regulation that had increasingly become central to American foreign policy after the terrorist attacks of September 11, 2001. Historically, emergency economic powers were originally intended to provide flexibility during wartime or major international crises. Over time, however, sanctions evolved into instruments of continuous strategic pressure. In the Cuban case, the 2026 order reflected Washington’s claim that Havana’s policies extended beyond domestic repression and posed broader threats to American interests in the Western Hemisphere.
The document’s policy declaration emphasized that the conduct of the Cuban government was “repugnant to the moral and political values of free and democratic societies.” Such language was consistent with decades of American criticism regarding restrictions on political opposition, freedom of expression, independent journalism, and civil society activity within Cuba. Since the revolutionary consolidation of power during the early 1960s, successive Cuban administrations had defended one-party socialist rule as necessary for protecting national sovereignty against foreign intervention. American administrations, by contrast, repeatedly portrayed Cuban governance as authoritarian. The 2026 order therefore formed part of a rhetorical tradition dating back to the administration of Dwight D. Eisenhower, who in 1960 began imposing trade restrictions following the expropriation of American assets on the island.
One of the most consequential sections of the order concerned the blocking of property and financial interests belonging to designated individuals and entities. The sanctions targeted foreign persons operating within the energy, defense, financial services, metals and mining, and security sectors of the Cuban economy. Historically, these sectors had long occupied a strategic position within the Cuban state structure. During the Soviet era between 1961 and 1991, Cuba depended heavily on subsidized oil shipments and economic support from Moscow, while the defense and security apparatus developed under close cooperation with Soviet intelligence and military institutions. After the collapse of the Soviet Union in December 1991, Cuba entered what became known as the “Special Period,” a severe economic crisis marked by shortages, rationing, and industrial decline. In subsequent decades, the Cuban leadership sought alternative economic partnerships with countries such as Venezuela, China, and Russia, particularly in the energy and mining sectors. The 2026 sanctions attempted to disrupt those external networks by threatening secondary consequences for international partners engaged with Havana.
The order also authorized sanctions against individuals determined to have materially assisted or supported the Cuban government, including through financial or technological services. This provision reflected the increasing sophistication of sanctions policy in the twenty-first century, where pressure mechanisms extended beyond direct state actors to include intermediaries, logistics providers, foreign banks, and multinational corporations. The approach resembled strategies previously employed against Iranian financial institutions during the 2010s, when access to the international banking system became a major instrument of coercion.
Another historically significant provision concerned allegations of human rights abuse and corruption. The order identified misappropriation of public assets, bribery, and expropriation for political purposes as sanctionable activities. Such accusations had long appeared in reports by American policymakers and dissident groups concerning the Cuban political system. The reference to expropriation carried particular historical weight because property seizures during the revolutionary years remained one of the most enduring disputes between Havana and Washington. After the revolutionary government nationalized American-owned sugar mills, utilities, refineries, and agricultural estates between 1959 and 1961, compensation disputes became central to the diplomatic rupture between the two nations.
The travel restrictions outlined in the order similarly reflected historical continuity. By suspending entry into the United States for individuals connected to the designated activities, the administration revived methods previously used against sanctioned officials from countries such as Venezuela, Russia, and Belarus. Cuban-American relations had always been shaped by migration politics. The first major wave of Cuban exiles arrived in Florida during the early 1960s, followed by later migrations such as the Mariel boatlift of 1980, when approximately 125,000 Cubans departed for the United States, and the balsero crisis of 1994, during which thousands attempted to cross the Florida Straits on improvised rafts. By 2026, Cuban-American communities, especially in Miami, remained influential participants in debates over sanctions and normalization.
The order’s provisions targeting foreign financial institutions represented one of its most expansive dimensions. The Secretary of the Treasury, in consultation with the Secretary of State, received authority to prohibit correspondent banking relationships and to block assets belonging to institutions facilitating significant transactions for sanctioned parties. This approach reflected broader transformations in international finance after the globalization of dollar-based transactions. Since the United States controls access to the world’s primary reserve currency and many major clearing systems, sanctions affecting correspondent accounts often possess extraterritorial consequences extending far beyond American territory.
Historically, American sanctions policy toward Cuba had fluctuated between confrontation and limited engagement. During the presidency of Barack Obama, a major shift occurred on December 17, 2014, when Obama and Cuban President Raúl Castro simultaneously announced steps toward normalization. Diplomatic relations were formally restored in July 2015, and the American embassy reopened in Havana after more than five decades. Commercial flights resumed, restrictions on remittances eased, and tourism increased substantially. Yet many elements of the embargo remained embedded in statutory law, particularly through the Helms–Burton Act of 1996, which codified sanctions and limited executive authority to remove them unilaterally.
The administration of Donald Trump during his first presidential term from 2017 to 2021 reversed several aspects of Obama-era rapprochement. Restrictions on travel, remittances, and business transactions were tightened, while Cuba was redesignated as a State Sponsor of Terrorism in January 2021 shortly before Trump left office. The 2026 executive order therefore appeared not as an isolated policy innovation but as part of a longer trajectory emphasizing maximum pressure against Havana.
The legal structure of the order was notable for its reliance on emergency powers rather than congressional legislation. Under the NEA and IEEPA, presidents possess broad authority to regulate commerce after declaring a national emergency linked to foreign threats. Since the passage of IEEPA in 1977, numerous administrations have used such powers to freeze assets, prohibit transactions, and restrict access to financial systems. Critics of this approach have argued that the repeated extension of national emergencies risks normalizing extraordinary executive authority. Supporters, however, contend that sanctions provide a nonmilitary mechanism for confronting hostile governments while avoiding direct armed conflict.
The order’s language concerning the absence of prior notice before sanctions designation reflected practical concerns within financial enforcement. American authorities argued that advance warning would permit targeted individuals or institutions to transfer assets beyond American jurisdiction. Such reasoning had become common in sanctions enforcement involving terrorism financing, organized crime, and transnational corruption investigations. By 2026, the Office of Foreign Assets Control (OFAC) within the Department of the Treasury had become one of the most influential agencies in the administration of global sanctions policy.
The Cuban government historically denounced American sanctions as violations of sovereignty and international law. Since 1992, the United Nations General Assembly had annually adopted resolutions criticizing the American embargo. Many governments in Latin America, Africa, and Europe argued that unilateral sanctions harmed ordinary Cuban citizens more than political elites. Cuban officials frequently described sanctions as an instrument of economic warfare designed to destabilize the socialist system established after the revolution. The 2026 order was therefore interpreted in Havana not merely as a legal document but as evidence of continued American hostility.
Economically, the impact of sanctions on Cuba had long been intertwined with broader structural weaknesses. The island’s economy struggled with declining productivity, limited foreign investment, chronic shortages, and dependence on external partners. Tourism became increasingly important after the 1990s, particularly visitors from Canada, Europe, and Latin America. However, tightening American restrictions often reduced opportunities for financial transactions, insurance, shipping, and investment. By targeting foreign institutions and companies interacting with Cuban entities, the 2026 order threatened to deepen the island’s international isolation.
The executive order also illustrated the evolution of sanctions into instruments of symbolic politics. American administrations frequently presented sanctions as demonstrations of solidarity with dissidents, political prisoners, and civil society activists. In Cuba, protests occurring on July 11, 2021, marked one of the largest nationwide demonstrations since the revolution, with citizens demanding greater political freedoms and improved living conditions. International scrutiny intensified after arrests and prosecutions connected to those protests. The 2026 order’s references to repression and human rights abuses drew heavily upon this context.
At the same time, historians of United States–Cuba relations have repeatedly observed that sanctions alone rarely achieve rapid political transformation. Despite more than six decades of economic restrictions, the Cuban political system endured through changes in leadership from Fidel Castro to Raúl Castro, and later to Miguel Díaz-Canel. The resilience of the Cuban state derived from a combination of nationalism, centralized political organization, security control, and external alliances. Consequently, debates surrounding sanctions often centered not only on morality or legality but also on effectiveness.
The concluding sections of the executive order dealt with definitions, implementation procedures, and agency coordination. These administrative provisions, though less publicly visible, were essential for translating presidential declarations into enforceable policy. The order directed the Department of State, the Department of the Treasury, and other executive agencies to adopt regulations, publish notices, and issue guidance necessary for implementation. Such bureaucratic mechanisms form the operational backbone of modern sanctions regimes, transforming broad political objectives into daily compliance obligations affecting banks, corporations, insurers, shipping companies, and travelers across multiple continents.
By the time the order was issued in May 2026, relations between the United States and Cuba had already endured nearly seven decades of confrontation, negotiation, exile politics, ideological rivalry, and intermittent diplomatic thaw. From the failed Bay of Pigs invasion in April 1961, to the Cuban Missile Crisis of October 1962, to the cautious normalization efforts of the 2010s, the relationship consistently reflected larger struggles over sovereignty, security, ideology, and hemispheric influence. The executive order signed by Donald Trump therefore stood not merely as a technical sanctions directive, but as another chapter in one of the longest-running geopolitical conflicts in modern American diplomatic history.
Sarvarthapedia Core Concept: United States–Cuba Relations
The central node connecting all themes in this network is the long-term relationship between the United States and Cuba, shaped by revolution, ideological conflict, sanctions, migration, diplomacy, and geopolitical rivalry since 1959.
Connected Concepts
- Cuban Revolution (1959)
- Cold War
- United States Sanctions Policy
- Executive Order of May 1, 2026
- National Security Doctrine
- Human Rights Diplomacy
- Economic Embargo
- Migration and Exile Politics
- Emergency Executive Powers
- Global Financial Enforcement
Executive Order of May 1, 2026
The executive order signed by Donald Trump in 2026 functions as a modern expansion of long-standing American sanctions policy toward Cuba.
Connected To
- International Emergency Economic Powers Act (IEEPA)
- National Emergencies Act (NEA)
- Office of Foreign Assets Control (OFAC)
- Secondary Sanctions
- State Sponsor of Terrorism Designation
- Human Rights Sanctions
- Financial Isolation
- Cuba–Russia Relations
- Cuba–China Relations
- Cuba–Venezuela Relations
Relationship with Other Concepts
- Revives Cold War-era containment logic.
- Extends earlier embargo frameworks established in 1962.
- Expands sanctions from trade restrictions into global financial enforcement.
- Connects domestic Cuban repression with international security narratives.
Cuban Revolution (1959)
The Cuban Revolution transformed Cuba from a United States-aligned republic into a socialist state allied with the Soviet Union.
Connected To
- Fidel Castro
- Nationalization of American Property
- Soviet Union
- Socialist Governance
- Anti-Imperialism
- Bay of Pigs Invasion
- Cuban Missile Crisis
- United States Embargo
Relationship with Other Concepts
- Triggered the collapse of pre-revolutionary US-Cuba economic relations.
- Led directly to sanctions and diplomatic rupture.
- Became the ideological foundation of modern Cuban nationalism.
- Established the one-party political structure criticized in later sanctions regimes.
Economic Embargo Against Cuba
The embargo represents the longest continuous sanctions regime in modern American foreign policy.
Connected To
- John F. Kennedy
- Trade Restrictions
- Helms–Burton Act (1996)
- Executive Orders
- Economic Warfare
- Property Expropriation
- International Criticism
Relationship with Other Concepts
- Originated after expropriation disputes.
- Became codified through congressional legislation.
- Serves as the historical predecessor to the 2026 sanctions expansion.
- Shapes Cuban economic isolation and foreign investment patterns.
International Emergency Economic Powers Act (IEEPA)
IEEPA provides the legal basis for many modern American sanctions regimes.
Connected To
- National Emergencies Act
- Executive Authority
- Financial Sanctions
- Asset Freezes
- OFAC
- Counterterrorism Policy
Relationship with Other Concepts
- Enables presidents to regulate international commerce during declared emergencies.
- Expanded significantly after September 11, 2001.
- Forms the legal architecture behind the 2026 Cuba sanctions order.
- Connects sanctions policy with national security governance.
National Emergencies Act (NEA)
The NEA institutionalized presidential emergency powers in foreign affairs.
Connected To
- Executive Power
- National Security
- Emergency Governance
- IEEPA
- Presidential Directives
Relationship with Other Concepts
- Allows recurring renewal of emergency sanctions regimes.
- Illustrates the normalization of extraordinary executive authority.
- Links Cold War emergency traditions to modern sanctions systems.
Office of Foreign Assets Control (OFAC)
OFAC became one of the central enforcement institutions of global American financial power.
Connected To
- Treasury Department
- Asset Blocking
- Financial Compliance
- Global Banking
- Correspondent Banking Restrictions
- Secondary Sanctions
Relationship with Other Concepts
- Implements sanctions operationally.
- Converts political directives into compliance obligations.
- Extends American influence through dollar-centered financial systems.
Secondary Sanctions
Secondary sanctions punish third parties interacting with sanctioned actors.
Connected To
- International Banking
- Extraterritorial Enforcement
- Iran Sanctions
- Globalization
- Correspondent Accounts
Relationship with Other Concepts
- Expanded sanctions beyond direct bilateral restrictions.
- Threatened foreign corporations and banks working with Cuba.
- Demonstrates globalization of American financial leverage.
Cold War
The Cold War created the ideological and geopolitical framework underlying the US-Cuba conflict.
Connected To
- Soviet Union
- Containment
- Communism vs Capitalism
- Cuban Missile Crisis
- Proxy Conflicts
- Nuclear Tensions
Relationship with Other Concepts
- Positioned Cuba as a frontline ideological battleground.
- Influenced American perceptions of Cuban security threats.
- Continues symbolically in modern sanctions rhetoric.
Cuban Missile Crisis (1962)
The Cuban Missile Crisis represented the most dangerous confrontation of the Cold War.
Connected To
- Soviet Union
- Nuclear Weapons
- John F. Kennedy
- National Security Doctrine
- Cuba–Soviet Alliance
Relationship with Other Concepts
- Cemented Cuba’s strategic significance in American security thinking.
- Reinforced long-term hostility and containment policies.
- Strengthened embargo justification during the Cold War.
Bay of Pigs Invasion (1961)
The failed American-backed invasion deepened Cuban mistrust toward the United States.
Connected To
- CIA Operations
- Anti-Castro Exiles
- Cuban Nationalism
- Cold War Interventionism
Relationship with Other Concepts
- Strengthened Fidel Castro’s domestic legitimacy.
- Accelerated Cuba’s alignment with the Soviet Union.
- Became a foundational memory in Cuban anti-imperialist discourse.
Human Rights Diplomacy
Human rights criticism became a major justification for sanctions policy.
Connected To
- Political Repression
- Civil Society
- Freedom of Expression
- July 11 Protests (2021)
- Political Prisoners
Relationship with Other Concepts
- Provides moral legitimacy for sanctions.
- Links domestic governance issues with international policy responses.
- Competes with sovereignty-based arguments advanced by Cuba.
July 11 Protests (2021)
The 2021 demonstrations marked one of the largest protest waves in revolutionary Cuban history.
Connected To
- Economic Crisis
- Political Dissent
- Internet Activism
- State Repression
- International Media Attention
Relationship with Other Concepts
- Intensified global scrutiny of Cuba’s political system.
- Influenced the rhetoric and justification of later sanctions.
- Became symbolic of civil resistance narratives.
Migration and Exile Politics
Migration profoundly shaped the political and emotional dimensions of US-Cuba relations.
Connected To
- Cuban-American Communities
- Miami Politics
- Mariel Boatlift (1980)
- Balsero Crisis (1994)
- Immigration Restrictions
Relationship with Other Concepts
- Created influential anti-Castro political constituencies in the United States.
- Linked foreign policy with domestic electoral politics.
- Reinforced sanctions advocacy within segments of the Cuban diaspora.
Mariel Boatlift (1980)
The Mariel migration wave transformed Cuban-American demographics.
Connected To
- Refugee Policy
- Fidel Castro
- Florida Politics
- Migration Crisis
Relationship with Other Concepts
- Demonstrated how political tensions produced migration pressures.
- Increased the domestic political salience of Cuba policy in the United States.
Balsero Crisis (1994)
The balsero crisis emerged during Cuba’s post-Soviet economic collapse.
Connected To
- Special Period
- Economic Hardship
- Raft Migration
- US Immigration Policy
Relationship with Other Concepts
- Reflected the humanitarian consequences of economic crisis.
- Linked sanctions debates with migration concerns.
Special Period
The Special Period refers to Cuba’s severe economic crisis after the collapse of the Soviet Union.
Connected To
- Soviet Collapse
- Food Shortages
- Energy Crisis
- Tourism Economy
- Economic Survival Strategies
Relationship with Other Concepts
- Forced Cuba to diversify international partnerships.
- Increased dependence on tourism and remittances.
- Reshaped Cuban economic policy after 1991.
Cuba–Russia Relations
Modern Cuba-Russia relations reflect continuity from Soviet-era alliances.
Connected To
- Energy Cooperation
- Defense Cooperation
- Soviet Legacy
- Geopolitical Multipolarity
Relationship with Other Concepts
- Became a target of sanctions enforcement.
- Reinforces American perceptions of strategic rivalry in the Western Hemisphere.
Cuba–China Relations
China emerged as an important economic and diplomatic partner for Cuba after the Cold War.
Connected To
- Trade Relations
- Infrastructure Investment
- Socialist Cooperation
- Alternative Global Partnerships
Relationship with Other Concepts
- Reduces Cuba’s economic dependence on Western systems.
- Complicates the effectiveness of American isolation strategies.
Cuba–Venezuela Relations
Venezuela became Cuba’s major energy partner during the post-Soviet era.
Connected To
- Oil Subsidies
- Hugo Chávez
- Socialist Alliances
- Regional Politics
Relationship with Other Concepts
- Helped Cuba survive after Soviet collapse.
- Became intertwined with broader US sanctions strategies in Latin America.
Barack Obama and Normalization (2014–2016)
Obama initiated the most substantial thaw in US-Cuba relations since the revolution.
Connected To
- Diplomatic Restoration
- Tourism Expansion
- Remittances
- Havana Embassy Reopening
- Raúl Castro
Relationship with Other Concepts
- Temporarily weakened isolationist policy trends.
- Demonstrated coexistence between engagement and ideological disagreement.
- Created a contrast later reversed by Trump-era policies.
Donald Trump and Maximum Pressure
Trump’s Cuba policy revived and intensified coercive sanctions strategies.
Connected To
- State Sponsor of Terrorism
- Travel Restrictions
- Financial Sanctions
- Executive Orders
- Anti-Normalization Policy
Relationship with Other Concepts
- Reversed major aspects of Obama-era rapprochement.
- Linked Cuba policy with broader anti-socialist rhetoric.
- Culminated in the 2026 executive order.
Sovereignty vs Intervention
One of the deepest conceptual conflicts in US-Cuba relations concerns the tension between sovereignty and external intervention.
Connected To
- Anti-Imperialism
- Human Rights Intervention
- International Law
- Economic Warfare
- National Self-Determination
Relationship with Other Concepts
- Cuba frames sanctions as violations of sovereignty.
- The United States frames sanctions as defense of democratic values.
- Shapes international disagreement over legitimacy of unilateral sanctions.
United Nations Criticism of the Embargo
The United Nations General Assembly repeatedly condemned the embargo.
Connected To
- International Law
- Multilateral Diplomacy
- Humanitarian Concerns
- Global South Politics
Relationship with Other Concepts
- Illustrates global opposition to unilateral sanctions.
- Contrasts American policy with broader international consensus.
Global Financial Enforcement
Modern sanctions increasingly operate through international banking systems rather than traditional military force.
Connected To
- Dollar Hegemony
- Correspondent Banking
- OFAC
- Financial Globalization
- Compliance Regimes
Relationship with Other Concepts
- Demonstrates transformation of economic power into geopolitical leverage.
- Extends American influence far beyond territorial jurisdiction.
Ideological Conflict
Ideological rivalry remains one of the enduring foundations of the US-Cuba confrontation.
Connected To
- Socialism
- Capitalism
- Anti-Communism
- Revolutionary Nationalism
- Liberal Democracy
Relationship with Other Concepts
- Sustains the symbolic dimension of sanctions.
- Shapes competing narratives about freedom, sovereignty, and legitimacy.
- Links twentieth-century Cold War dynamics to twenty-first-century policy debates.
Original Text of the Executive Order
IMPOSING SANCTIONS ON THOSE RESPONSIBLE FOR REPRESSION IN CUBA AND FOR THREATS TO UNITED STATES NATIONAL SECURITY AND FOREIGN POLICY
Executive Orders
May 1, 2026
By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), section 212(f) of the Immigration and Nationality Act of 1952 (8 U.S.C. 1182(f)), and section 301 of title 3, United States Code, and in order to take further steps with respect to the national emergency declared in Executive Order 14380 of January 29, 2026 (Addressing Threats to the United States by the Government of Cuba), I hereby determine and order:
Section 1. Policy. The policies, practices, and actions of the Government of Cuba, as described in Executive Order 14380, continue to constitute an unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security and foreign policy of the United States. Not only are these policies, practices, and actions designed to harm the United States, but they are also repugnant to the moral and political values of free and democratic societies.
Sec. 2. Sanctionable Conduct. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States persons of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in:
(i) any foreign person determined by the Secretary of State, in consultation with the Secretary of the Treasury; or by the Secretary of the Treasury, in consultation with the Secretary of State:
(A) to operate in or have operated in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, or any other sector of the Cuban economy, as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;
(B) to be owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
(C) to own or control, directly or indirectly, any person whose property or interests in property are blocked pursuant to this order;
(D) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
(E) to be or have been a leader, official, senior executive officer, or member of the board of directors of the Government of Cuba or an entity whose property or interests in property are blocked pursuant to this order;
(F) to be a political subdivision, agency, or instrumentality of the Government of Cuba;
(G) to be responsible for or complicit in, or to have directly or indirectly engaged in or attempted to engage in, serious human rights abuse in Cuba;
(H) to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, corruption related to Cuba, including corruption by, on behalf of, or otherwise related to the Government of Cuba, or a current or former official at any level of the Government of Cuba, such as the misappropriation of public assets, expropriation of private assets for personal gain or political purposes, or bribery; or
(I) to be an adult family member of a person designated pursuant to this order.
(b) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that are issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted prior to the date of this order; except that this subsection shall not apply to activities authorized by, and shall not affect the validity of, any license issued pursuant to part 515 of chapter 31 of the Code of Federal Regulations.
(c) Except to the extent required by section 203(b) of IEEPA (50 U.S.C. 1702(b)), or provided in regulations, orders, directives, or licenses that are issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted prior to the date of this order:
(i) any transaction or dealing by United States persons or within the United States in property or interests in property blocked pursuant to this order is prohibited, including but not limited to the making or receiving of any contribution of funds, goods, or services to or for the benefit of those persons whose property or interests in property are blocked pursuant to this order;
(ii) any transaction by any United States person or within the United States that evades or avoids, or has the purpose of evading or avoiding, or attempts to violate, any of the prohibitions set forth in this order is prohibited; and
(iii) any conspiracy formed to violate any of the prohibitions set forth in this order is prohibited.
(d) I hereby determine that the making of donations of the type specified in section 203(b)(2) of IEEPA (50 U.S.C. 1702(b)(2)) by United States persons to persons determined to be subject to subsection (a) of this section would seriously impair my ability to deal with the national emergency declared in Executive Order 14380, and I hereby prohibit such donations.
(e) For those persons determined to be subject to subsection (a) of this section who might have a constitutional presence in the United States, I find that, because of the ability to transfer funds or assets instantaneously, prior notice to such persons of measures to be taken pursuant to this order would render these measures ineffectual. I therefore determine that, for these measures to be effective in addressing the national emergency declared in Executive Order 14380, there need be no prior notice of a listing or determination made pursuant to subsection (a) of this section.
Sec. 3. Travel. (a) I hereby find the unrestricted immigrant and nonimmigrant entry into the United States of aliens determined to meet one or more of the criteria in section 2(a)(i) of this order would be detrimental to the interests of the United States, and I hereby suspend entry into the United States, as immigrants or nonimmigrants, of such persons, except where the Secretary of State, or the Secretary of State’s designee, determines that the person ‘s entry is in the national interest of the United States. Such persons shall be treated in the same manner as persons covered by section 1 of Proclamation 8693 of July 24, 2011 (Suspension of Entry of Aliens Subject to United Nations Security Council Travel Bans and International Emergency Economic Powers Act Sanctions).
Sec. 4. Foreign Financial Institutions. (a) The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized to impose on a foreign financial institution one or more of the sanctions described in subsection (b) of this section upon determining that the foreign financial institution has conducted or facilitated any significant transaction or transactions for or on behalf of any person whose property or interests in property are blocked pursuant to this order.
(b) With respect to any foreign financial institution determined to meet the criteria set forth in subsection (a) of this section, the Secretary of the Treasury, in consultation with the Secretary of State, may:
(i) prohibit the opening of, or prohibit or impose strict conditions on the maintenance of, correspondent accounts or payable-through accounts in the United States; and
(ii) block all property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of such foreign financial institution, and provide that such property and interests in property may not be transferred, paid, exported, withdrawn, or otherwise dealt in. The prohibitions described in this subsection shall include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property or interests in property are blocked pursuant to this subsection; and the receipt of any contribution or provision of funds, goods, or services from any such person.
(c) The sanctions described in subsection (b) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted before the date of this order; except that this subsection shall not apply to activities authorized by, and shall not affect the validity of, any license issued pursuant to part 515 of chapter 31 of the Code of Federal Regulations.
(d) I hereby determine that the making of donations of the types of articles specified in section 203(b)(2) of IEEPA (50 U.S.C. 1702(b)(2)) by, to, or for the benefit of any person whose property or interests in property are blocked pursuant to subsection (b) of this section would seriously impair my ability to deal with the national emergency declared in Executive Order 14380, and I hereby prohibit such donations.
Sec. 5. Delegation. Consistent with applicable law, the Secretary of State and the Secretary of the Treasury are directed and authorized to take all actions necessary to implement and effectuate this order — including through temporary suspension or amendment of regulations or through notices in the Federal Register and by adopting rules, regulations, or guidance — and to employ all powers granted to the President, including by IEEPA, as may be necessary to implement this order. The head of each executive department and agency (agency) is authorized to and shall take all appropriate measures within the agency’s authority to implement this order. The head of each agency may, consistent with applicable law, including section 301 of title 3, United States Code, redelegate the authority to take such appropriate measures within the agency.
Sec. 6. Reporting Directives. The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized and directed to submit recurring and final reports to the Congress on the national emergency declared in, and authorities exercised by, Executive Order 14380, consistent with section 401 of the NEA (50 U.S.C. 1641) and section 204(c) of IEEPA (50 U.S.C. 1703(c)).
Sec. 7. Definitions. For the purposes of this order:
(a) the term “entity” means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization;
(b) the term “Government of Cuba” means the Government of Cuba, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Cuba, and any person owned, controlled, or acting for or on behalf of, the Government of Cuba;
(c) the term “person” means an individual or entity;
(d) the term “United States person” means any United States citizen, lawful permanent resident, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches of such entities), or any person in the United States; and
(e) the term “foreign financial institution” means any foreign entity that is engaged in the business of accepting deposits; making, granting, transferring, holding, or brokering loans or credits; purchasing or selling foreign exchange, securities, futures, or options; or procuring purchasers and sellers thereof, as principal or agent. It includes but is not limited to depository institutions; banks; savings banks; money services businesses; operators of credit card systems; trust companies; insurance companies; securities brokers and dealers; futures and options brokers and dealers; forward contract and foreign exchange merchants; securities and commodities exchanges; clearing corporations; investment companies; employee benefit plans; dealers in precious metals, stones, or jewels; and holding companies, affiliates, or subsidiaries of any of the foregoing. The term does not include the international financial institutions identified in 22 U.S.C. 262r(c)(2), the International Fund for Agricultural Development, the North American Development Bank, or any other international financial institution so notified by the Office of Foreign Assets Control.
Sec. 8. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:
(i) the authority granted by law to an executive department or agency, or the head thereof; or
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
(d) The costs for publication of this order shall be borne by the Department of State.
DONALD J. TRUMP
THE WHITE HOUSE,
May 1, 2026.
