Latest / Trade Compliance Brief - Export Control and Sanctions Insights
US Cuba Sanctions Update: The May 1st EO, Sectoral Sanctions, and FFI Secondary Risks
On May 1, 2026, a sweeping new Executive Order fundamentally reshaped U.S. sanctions policy toward Cuba. Moving beyond the traditional list-based approach, this new framework introduces Sectoral Sanctions and high-stakes Secondary Sanctions for Foreign Financial Institutions (FFIs). In this brief, we analyze the "Russia Playbook" application to Cuba and what it means for global compliance programs.
In this episode, we cover:
The Sectoral Pivot: Identifying the five newly targeted sectors: Energy, Defense, Metals/Mining, Financial Services, and Security.
The FFI "Death…
The skinny
The skinny isn't ready yet — notes appear once the transcript is processed.