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IncreasingHigh2026-08-02

OFAC issues Cuba general licenses and updates SDN designations

Banking SupervisionOtherSanctionsCross-JurisdictionalUnited StatesConf: High
Regulatory Event

OFAC issued Cuba General Licenses 2, 3, and 4 authorizing wind-down and specific transactions involving CEIBA Investments Limited and third-country missions, alongside counter-terrorism and counter-narcotics designations.

Analysis

OFAC's simultaneous action combines new Cuba-related general licenses with counter-terrorism and counter-narcotics designations plus a Belarus delisting. Institutions with Cuba exposure must evaluate whether transactions qualify under GL 2, 3, or 4, particularly involving CEIBA Investments Limited debt, equity, or derivatives.

Relevance

Sanctions list changes and new general licenses directly affect transaction screening, correspondent banking, and trade finance controls across global operations.

Required Action

Action Required

Screen counterparties against updated SDN list and assess CEIBA exposure to determine reliance on new general licenses before wind-down deadlines.

Justification

Multi-program OFAC action affecting Cuba, terrorism, narcotics, and Belarus sanctions programs simultaneously requires immediate screening recalibration.

Control Commentary

Sanctions screening controls updated to reflect new OFAC designations and Cuba general licenses. CEIBA-related exposures under review; wind-down authorizations to be documented and monitored against license expiry.

Source

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Cuba General License 2, 'Authorizing the Wind Down of Transactions Involving CEIBA Investments Limited;' Cuba General License 3, 'Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, CEIBA Investments Limited;' and Cuba General License 4, 'Authorizing Transactions for Third-Country Official Missions in Cuba.' Additionally, OFAC has updated the Specially Designated N

RH-2026-07-28-008