Sanctioning Cuba’s State-Owned Oil and Gas Company Unión Cuba-Petróleo

Like every resource on the island, energy has long been weaponized by Cuba’s Communist government as a tool of both repression and self-serving regime kleptocracy.  While the Cuban people have suffered fuel shortages and blackouts because of decades of under-investment in critical infrastructure, Cuba’s Communist leaders have diverted energy resources to line their own pockets:  reselling countless barrels of scarce energy on the secondary market, hoarding energy supplies for its military, intelligence and repressive forces, and rationing energy as a tool of social control.  As regular Cubans wait for weeks to fill their cars and suffer relentless blackouts, the Castro family flies around on a private jet, the government buses in fake protesters for publicity stunts, and the regime prioritizes keeping the power on in luxury tourist hotels.

That is why, today, I am designating Cuba’s state-owned oil and gas company Union Cuba-Petroleo (CUPET), key assets of which were unlawfully expropriated from American owners years ago, pursuant to President Trump’s Executive Order (E.O.) 14404 of May 1, 2026.  CUPET is being designated pursuant to Section 2(a)(i)(A) of E.O. 14404, for operating or having operated in the energy sector of the Cuban economy.  The Trump Administration will continue to target Cuba’s ability to leverage energy trade to further its corrupt agenda and repressive security apparatus. 

The Department’s actions are being taken pursuant to E.O. 14404, which authorizes sweeping sanctions on Cuba, including persons who support the Cuban regime’s security apparatus and those responsible for repression in Cuba and threats to U.S. national security.  Today’s action also furthers the objectives of the national emergency declared in E.O. 14380, “Addressing Threats to the United States by the Government of Cuba” and the National Security Presidential Memorandum 5 (NSPM-5), which direct the Executive Branch to improve human rights, encourage the rule of law, foster free markets and free enterprise, and promote democracy in Cuba.      

Sanctions Implications

As a result of today’s sanctions-related actions, and in accordance with E.O. 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy,” all property and interests in property of the designated  entity described above that are in the United States or in possession or control of U.S. persons are blocked and must be reported to the Department of the Treasury’s Office of Foreign Assets Control (OFAC).  Additionally, all entities that are owned individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.   

All transactions and dealings by U.S. persons or persons within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt.  These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.  Foreign persons who engage in transactions with persons designated pursuant to E.O. 14404—or that operate in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, as identified in E.O. 14404—are themselves at risk of sanctions.  Non-U.S. persons, including foreign financial institutions, should proceed with caution in any dealings with a party sanctioned under this authority.  Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.  All property and interests in property of persons that are blocked pursuant to the Cuban Assets Control Regulations (CACR) continue to be blocked.  The CACR prohibits persons subject to U.S. jurisdiction from dealing in property in which Cuba or a Cuban national has an interest, unless authorized or exempt.

The power and integrity of U.S. government sanctions derive not only from the U.S. government’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law.  The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.  

Petitions for removal from the SDN List may be sent to: OFAC.Reconsideration@treasury.gov.  Petitioners may also refer to the Department of State’s Delisting Guidance page.