We refer to previous information on sanctions against Cuba. On 1 May 2026, the United States issued Executive Order 14404. This order significantly increases sanctions risks for non-US persons and companies, including shipowners, charterers and service providers in the maritime sector.
Key Elements of the New Executive Order – The EO authorises the imposition of sanctions on foreign persons who:
- Operate or have operated in specified sectors of the Cuban economy, including:
- Energy
- Metals and mining
- Financial services
- Security
- Any other sector of the Cuban economy as may later be determined by the US authorities
- Have materially assisted, sponsored, or provided financial, material, technological support, or goods or services to the Government of Cuba or any blocked person. On 7 May 2026, the first new designations under this EO were published:
- Grupo De Administracion Empresarial S.A. (Gaesa)
- Ania Guillermina Lastres Morera (Lastres)
- Moa Nickel Sa (Mnsa)
The US Office of Foreign Assets Control (OFAC) simultaneously published FAQs emphasising that foreign financial institutions also face risks when conducting significant transactions with blocked persons.
These measures broaden the existing Cuba sanctions (CACR) and create new exposure for non-US operators involved in trade, financing or services linked to Cuba-related entities. This may result in the blocking of accounts or assets or access to the US financial system.
Advice to Members and Clients:
- Conduct thorough due diligence on counterparties, vessels, cargoes and routes with any possible Cuba connection.
- Maintain detailed records of all checks and communications.
- Continuously monitor OFAC and other official lists.
- Avoid, where possible, transactions with heightened risk and consider alternative trading partners.
- Ensure your charterparty agreement contain appropriate sanction clauses.
For specific advice on planned operations or ongoing matters, please contact our Claims team at claims@nnpc-marine.com. NNPC Marine Insurance continues to monitor developments closely and will keep you informed of relevant updates.
