OFAC Publishes Cuba Sanctions Regulations, Amending CACR
Treasury's OFAC on September 29, 2026 published a new Cuba Sanctions Regulations framework at 31 C.F.R. Part 516 implementing Executive Order 14404, alongside amendments to the Cuban Assets Control Regulations.
OFAC announced on September 29, 2026 that it had published the Cuba Sanctions Regulations (CSR) as a new framework codified at 31 C.F.R. Part 516, implementing Executive Order 14404, and had concurrently amended the Cuban Assets Control Regulations (CACR). The change is structural rather than incremental: a full country-specific sanctions program now sits in its own part of the Code of Federal Regulations, reshaping the prior CACR-only architecture for Cuba-related restrictions.
For sanctions and export-control practices, this relocates and re-baselines the compliance obligations attaching to Cuba transactions. Screening logic, licensing procedures, reporting duties and recordkeeping expectations for blocked or denied dealings will now key off Part 516 rather than the CACR alone. Banks, corporates, shipping and commodity counterparties with residual Cuba exposure, and counsel handling joint ventures or carve-outs tied to Cuban assets, need existing program policies re-mapped to the new structure.
One caution: this cluster contains a single Holland & Knight client alert. The operative OFAC text, effective dates, transition provisions from the CACR and any enforcement signals were not independently reviewed and should be confirmed against the Federal Register publication and OFAC guidance.
Practical next step: pull the regulatory text, diff it against current Cuba program policies, and confirm whether general or specific licenses issued under the CACR remain valid or require re-issuance under Part 516.