On September 3, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated six Cuban targets to the Specially Designated Nationals (SDN) List under Executive Order 14404, issued Cuba General License 4A, and removed one Russia-related entity from the SDN List. The designations take effect immediately on publication and carry strict civil liability under 31 CFR Part 501, so any bank, importer or screening system touching U.S. dollars or Cuba must update its filters the same day.
The package spans a bank, petroleum and nickel state-owned enterprises, and an individual linked to the Castro family. Cuba General License 4A separately authorizes transactions for third-country diplomatic and consular missions in Cuba, while the delisting of Dulac Capital Ltd frees a previously blocked Russia-related entity under Executive Order 14024. The full text is in OFAC's September 3, 2026 release.
Which entities did OFAC add to the SDN List, and what is the compliance effect?
OFAC added the following Cuban targets, all tagged under Executive Order 14404, effective September 3, 2026:
| Entity | Type | Sector and identifier |
|---|---|---|
| Banco Exterior de Cuba | Financial institution | SWIFT/BIC BECUCUHH, Havana |
| Comercial Cupet S.A. | State-owned enterprise | Wholesale of fuels, Havana |
| Empresa Importadora de Abastecimiento para el Petroleo (ABAPET) | State-owned enterprise | Petroleum, linked to Union Cuba Petroleo |
| Empresa Importadora y Abastecedora del Niquel (CEXNI) | State-owned enterprise | Nickel, Moa, Holguin |
| Empresa de Servicios Comandante Rene Ramos Latour (NICAROTEC) | State-owned enterprise | Mining support, Mayari, Holguin |
| Castro Calis, Fidel Ernesto | Individual | DOB 16 May 1995, linked to Alejandro Castro Espin |
Once listed, these targets are blocked: U.S. persons and anyone in the United States must freeze any property or interest in property of the designees and report them to OFAC. The 50 Percent Rule applies, meaning any entity 50 percent or more owned in the aggregate by one or more blocked persons is itself blocked even when not separately named, so compliance teams must map ownership chains rather than rely on exact-name matches alone.
Who must update screening systems, and by when?
The designations are effective immediately, and OFAC enforces a strict-liability regime: civil penalties attach without proof of intent under 31 CFR Part 501, the Reporting, Procedures and Penalties Regulations. The practical consequence is that screening systems, watch-list filters and transaction-monitoring rules must be updated the same day to avoid processing a prohibited transaction.
Three audiences carry the heaviest exposure. Correspondent banks and any institution clearing U.S. dollars must block payments touching Banco Exterior de Cuba (SWIFT/BIC BECUCUHH), because OFAC jurisdiction follows the dollar, not the domicile of the bank. Petroleum importers and traders must screen Comercial Cupet and ABAPET, which handle wholesale fuel distribution. Nickel importers and metals traders must screen CEXNI, a Moa-based importer tied to Cuba's nickel exports. Voluntary self-disclosure of a violation materially reduces the penalty, with up to 50 percent mitigation under the OFAC enforcement guidelines.
What does Cuba General License 4A authorize?
Alongside the designations, OFAC issued Cuba General License 4A, "Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba." A general license is a standing authorization: eligible parties do not need to apply for a specific license, but they must keep records showing each transaction fell within the license's scope and conditions. Banks processing payments for third-country embassies and consulates in Cuba should confirm the activity fits the license before relying on it, and verify the counterparty is not itself an SDN.
What changes with the Dulac Capital removal?
OFAC removed Dulac Capital Ltd and its three Russian representative-office aliases from the SDN List. Dulac Capital was designated under Executive Order 14024, the Russia sanctions authority. A removal means the entity is no longer blocked, and funds frozen solely because of that designation may be unblocked, provided no other sanctions program continues to apply. Compliance teams should not treat the delisting as a blanket clearance: the original listing carried secondary-sanctions risk under Section 11 of Executive Order 14024, and parties must confirm no other listing or license condition restricts the relationship before releasing funds.
Continuous, per-jurisdiction real-time monitoring surfaces SDN list changes the moment OFAC publishes them, so screening teams act before a transaction clears rather than after.
Subscribe to the free newsletter
Push the six new identifiers, including SWIFT/BIC BECUCUHH, into your screening system today. Re-screen open Cuba exposure across banking, petroleum and nickel counterparties, applying the 50 Percent Rule to ownership chains. Verify whether any frozen Dulac Capital funds can now be released, and confirm no other sanctions authority blocks the release. Brief your front office that Cuba General License 4A is available for qualifying third-country diplomatic-mission transactions, and document the reliance.
