In short
- OFAC is eliminating over 100 subparts from its chapter of the CFR, as stated by OFAC.
- OFAC is issuing five new Cuba-related FAQs (1271–1275) and 29 amended FAQs, per OFAC.
What happened
OFAC has published regulatory amendments, including new Cuba Sanctions Regulations to implement E.O. 14404 of May 1, 2026, and changes to the Cuban Assets Control Regulations, 31 C.F.R. Part 515. These rules will take effect upon publication in the Federal Register on September 30, 2026.
The agency is also removing over 100 duplicative subparts from its chapter of the CFR and making information on delegations of authority, recordkeeping, and reporting requirements easier to locate. OFAC issued five new Cuba-related FAQs (1271–1275), 29 amended FAQs, and an OFAC Alert highlighting increased sanctions risks for Cuba-related transactions.
OFAC is also publishing regulations to implement E.O. 14404 of May 1, 2026, "Imposing Sanctions on Those Responsible for Repression in Cuba and Threats to the United States National Security and Foreign Policy.
In numbers
- over 100 subparts eliminated from OFAC's chapter of the CFR
- 29 amended Cuba-related Frequently Asked Questions
Named in this item
Organization, regulator US OFAC Cuba Sanctions —
What compliance teams should check
- Review the amended Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR), for updated compliance requirements.
- Update internal policies to reflect the new and amended Cuba-related FAQs (1271–1275 and 29 amended FAQs) issued by OFAC.
- Assess transaction screening procedures in light of the OFAC Alert, "Expanded Sanctions Against Cuba," for increased sanctions risks.
Why it matters
These regulatory amendments and new guidance from OFAC significantly impact compliance obligations for transactions involving Cuba. The implementation of E.O. 14404 and changes to the Cuban Assets Control Regulations may introduce new restrictions and reporting requirements. The removal of over 100 CFR subparts streamlines regulatory references, while the new and amended FAQs and OFAC Alert provide updated risk information. Compliance officers must promptly adapt controls and procedures to ensure adherence to the revised sanctions framework and mitigate exposure to enforcement actions.
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