07 July 2025

President Trump has signed a National Security Memorandum, tightening and extending significantly US sanctions on Cuba.

The order is expected to expose non-US companies to greater secondary US sanctions risk if they transact or do business with any of the many Cuban enterprises and their subsidiaries that are linked to Cuban military and certain other state enterprises. The related regulations are expected to be published in early August.

The 30 June security memorandum instructs Cabinet members and federal agencies to seek to end “economic practices that disproportionately benefit the Cuban government or its military, intelligence, or security agencies or personnel at the expense of the Cuban people.”

Approach intended to widen extraterritorial nature of sanctions

The 30 June memorandum, in part, is intended to extend secondary sanctions in such a way as to prevent or deter businesses and entities in third countries from trading with and investing in Cuba. The approach was trailed earlier this year by the outgoing US Special Envoy for Latin America, Mauricio Claver-Carone. (See Cuba Briefing 10 March 2025).

A day after the document was signed by President Trump, the Miami Herald, citing ‘a source with knowledge of the new regulations’ reported that “the Trump administration will punish foreign companies that do business with military companies in Cuba.” According to the publication’s unnamed source, “sanctions will target any company providing direct or indirect support to companies directly or indirectly owned by the Cuban military,” thereby effectively expanding the US embargo to affect companies from third countries.

If this proves to be correct, among the international companies and smaller US businesses that may now be affected are those providing services, investing in, or trading with sectors including tourism, energy, fuel supply, telecoms, mineral extraction, financial services, port operations, the Mariel Economic Development Zone, and a wide range of other economic activities including those involving the supply of food, spares and equipment all of which Cuban military enterprises are closely involved in.

In this context the new security memorandum specifically mentions the military linked Cuban conglomerate GAESA which has many subsidiaries that overseas companies commonly transact their Cuba related business through. As such the yet to be published regulations could affect, for example, overseas business relationships with Gaviota that owns the hotels leased to or run by foreign hotel chains from Canada, Spain, Indonesia, India, Portugal and elsewhere. GAESA subsidiaries also operate many grocery stores, logistics operations, service stations, and other businesses in Cuba in convertible currency, sometimes undertaking such arrangements through subsidiaries based in third countries.

Number of sanctioned Cuban officials to increase significantly

Also affecting overseas engagement with Cuba, the memorandum instructs the US Treasury to significantly expand the number of sanctioned ministers, vice ministers, officials above a certain rank, senior trades unionists, senior media professionals, and members and employees of the Supreme Court.

The extended US sanctions list is also expected to include members and employees of the National Assembly; members of any provincial assembly; higher level officials of all Cuban ministries and state agencies; employees of the Ministry of the Interior and the Ministry of the Armed Forces; and sector heads of the Committees for the Defence of the Revolution.

New regulations expected in 30 days

The Presidential directive, which is now with leading US Cabinet members and the heads of multiple US government agencies, requires them to review US policy toward Cuba, examine current sanctions, respond to the new objectives set, and enforce or make stronger within 30 days the proposed actions.

To achieve this, the document mandates that “within 30 days of the date of this memorandum, the Secretary of the Treasury and the Secretary of Commerce, as appropriate, and in coordination with the Secretary of State and the Secretary of Transportation, will initiate a process to adjust current regulations relating to transactions with Cuba.”

This will require the State Department identifying Cuban entities or sub-entities such as GAESA, “under the control of, or act for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel,” where their direct or indirect financial transactions disproportionately “benefit such services or personnel at the expense of the Cuban people or private enterprise.” In such cases “direct or indirect” financial transactions will be prohibited.

The executive order further includes measures that seek to :

• Prioritise, making more effective “adherence to the statutory ban on US tourism to Cuba” by extending related measures introduced during the President’s first term.

• Require mandatory record-keeping of all US Cuba travel-related transactions for at least five years.

• Restrict US educational tours to groups by requiring that educational travel is for legitimate educational purposes and organised and run only by US citizensunder the auspices of an organisation subject to the jurisdiction of the US with a representative of the sponsoring body accompanying such travellers.

• Require the US Treasury to conduct regular audits of travel to Cuba.

• Seek to expand internet access and the unimpeded flow of information to Cubans.

• Oppose calls “in the United Nations and other international forums” to lift the US embargo “until a transitional government is established in Cuba,” and to submit “periodic reports on whether the conditions for a transitional government exist in Cuba.”

• End the “wet foot, dry foot” policy which the White House says “encouraged thousands of Cuban citizens to risk their lives to travel illegally to the United States,” by not reinstating the Cuban Adjustment Act.

• Increase efforts to support the Cuban people through the expansion of internet services, press freedom, free enterprise, free association, and legal travel.

• Require the US Attorney General to submit a report to the president within 90 days “on matters related to fugitives from US justice living in Cuba or being harboured by the Cuban government.”

• Convene a working group, comprised of relevant agencies, including the Cuban Broadcasting Office, and appropriate non-governmental organisations and private sector entities, to examine technological challenges and opportunities for expanding Internet access in Cuba.

• Develop programmes and activities through the Federal Government that “foster freedom of expression through independent media and Internet freedom so that the Cuban people may enjoy the free and unregulated flow of information.”

The document also includes a series of catch-all objectives indicating that US interests in Cuba include: advancing human rights; encouraging the growth of a Cuban private sector independent of government control; enforcing final orders of removal against Cuban nationals in the United States; protecting the national security and public health and safety of the US, including through “proper engagement on criminal cases;” working to ensure the return of fugitives from American justice living in Cuba; supporting US agriculture and protecting plant and animal health; advancing the understanding of the US regarding scientific and environmental challenges; and facilitating safe civil aviation.

The Security Memorandum makes clear that the new measures should not eliminate US actions that in Washington’s eyes provide tools to engineer change in Cuba. These include “supporting programmes to build democracy in Cuba; air and sea operations that support permitted travel, cargo, or commerce; the acquisition of visas for permitted travel; the expansion of direct telecommunications and internet access; and the sale of agricultural products, medicines, and medical devices sold to Cuba as allowed for under US legislation.

The text also indicates that the updated policy should not affect “the sending, processing, or receiving of authorised remittances” or seek to “otherwise promote the national security or foreign policy interests of the United States.”

According to preamble to the body of the text, White House Cuba policy in future “will be guided by the national security and foreign policy interests of the United States, as well as by solidarity with the Cuban people.” Its text however makes clear that the Trump Administration “will continue to evaluate its policies.”

The full text of the memorandum can be found at: https://www.whitehouse.gov/presidential-actions/2025/06/national-security-presidential-memorandum-nspm-5/

An accompanying White House fact sheet on the order can be read at: https://www.whitehouse.gov/fact-sheets/2025/06/fact-sheet-president-donald-j-trump-strengthens-the-policy-of-the-united-states-toward-cuba/

Cuba says new US policy aggressive and hegemonic

In an initial response, President Díaz-Canel condemned the measures announced by the White House as a continuation of a “merciless economic war” that severely limits the possibilities for the country’s commercial and financial development. Writing on X, he observed that the US Administration’s new aggressive plan against Cuba, responds to narrow US interests. The goal, he said is “to cause as much damage and suffering as possible to the people. The impact will be felt, but we will not be defeated.”

Speaking live on the television programme Mesa Redonda on 2 July, Cuba’s Deputy Foreign Affairs Minister, Carlos Fernández de Cossío, said that the Memorandum serves to justify the actions the White House is already implementing or will adopt in the future. The measures will, he said “cause suffering to the people, affecting the economy and the country’s development in sensitive areas such as tourism, fuel supply, electricity generation , food production, and many other areas.” The memorandum, he said threatens individuals and companies that legally export to the Caribbean country from the United States to Cuba’s private sector. He stressed, however, that Cuba has overcome moments of greater complexity. Today “we have the capacity, organisation, wisdom, and experience to overcome this new aggression from the imperialist power,” he told viewers.

In a formal statement Cuba’s Ministry of Foreign Affairs (MINREX) categorically “denounced and rejected” the latest “infamous document” and an earlier version produced by the first Trump Administration in June 2017. It described the new US Security Memorandum as a clear expression “of that country’s aggressive behaviour,” observing that its objective, is “economic coercion as a weapon of aggression against a sovereign country, with the aim of breaking the political will of the entire nation and subjecting it to the hegemonic dictatorship of the US.”

“The rulers and politicians of the United States have the audacity to declare that they act in this way for the good of the Cuban people,” MIREX wrote. Indicating that “the challenges Cuba faces are significant and daunting,” MINREX noted, “The US government doesn’t care that Cuba is a peaceful, stable, supportive country with friendly relations with virtually the entire world. Its policy serves the narrow interests of a corrupt, anti-Cuban clique that has made aggression against its neighbours a way of life and a very lucrative business.”

Security memorandum creates new uncertainties

The US National Security Memorandum was signed just days before Cuba’s Communist Party and its National Assembly were due to meet, in part to review the delivery of its slow-moving macroeconomic reform process, first announced in December 2023. It comes as the Cuban government and Communist Party continue to call for unity in the face of economic and social uncertainty as they try to address administrative failures, continuing shortages of food and essential supplies, power outages, a lack of fuel, and inadequate foreign exchange.

Although the Trump administration claims that its objective is change led by the Cuban people, the new policy if strictly enforced by Washington appears likely to create new hardships, increasing the possibility of illegal migration and social instability. Paradoxically, It comes at a time when the US is also seeking to remove to Cuba or elsewhere, the tens of thousands of Cubans who migrated legally to the US under the Biden era humanitarian parole programme; a measure that offered a pathway to eventual US citizenship.

How the Cuban government responds beyond rhetoric to the tightening of sanctions remains to be seen. If the new sanctions significantly further restrict the country’s ability to earn foreign currency and trade with existing international partners and the daily experience of many Cubans worsens, despite the strength of Cuban nationalism, it appears likely that the Communist Party and government, may find themselves subject to new domestically led social and political pressure.

Equally uncertain is the reaction of Cuba’s increasingly close allies, China and Russia, and its other hemispheric and western trade and investment partners. China, which rapidly condemned the new US measures (see China section in the full issue) and Russia, in different ways, have been seeking new economic and strategic opportunity in Cuba.

While the Trump Administration’s actions may strengthen their hand, less certain is how the island’s trading partners in Europe, Canada, Mexico, Brazil and elsewhere will react. They oppose US extraterritoriality and sanctions in relation to Cuba. Instead, they largely want to see gradual economic and political reform enabling the emergence of stable more liberal market-oriented Cuban political system. However, in the face of their overriding desire to retain a positive relationship with Washington, their reaction when the new regulations are published, will be telling.

Highlights in this issue:

• Cuban companies and individuals exempted from duties on renewable energy related imports
• Russian Transport Ministry seeking alternative funding for Cuban railways upgrade
• Air China inaugurates direct air cargo service to and from Havana
• Spain activates US$442mn Cuba debt conversion programme
• Cuba tells Eurasian Bloc leaders island can become their logistics bridge to Latin America

07 July 2025, Issue 1287

 The Caribbean Council is able to provide further detail about all of the stories in Cuba Briefing. If you would like a more detailed insight into any of the content of today’s issue, please get in touch.