Cuba Sanctions Compliance

Cuba is subject to a comprehensive US embargo administered by OFAC under the Cuban Assets Control Regulations, one of the longest-standing US sanctions programs. Almost all exports of US-origin goods and services to Cuba are prohibited without an OFAC license. Limited license exceptions exist for certain humanitarian goods, agricultural products, and telecommunications equipment, but these require careful documentation and compliance with specific conditions. US companies with Cuban-connected partners anywhere in their supply chain — including third-country intermediaries — face significant sanctions exposure. The embargo applies to US persons and US-origin goods globally, regardless of where the transaction originates.