OFAC expands Cuba controls and removes more than 100 regulatory subparts

On September 29, 2026, OFAC announced regulations implementing Executive Order 14404 on repression in Cuba, amendments to the Cuban Assets Control Regulations and 34 new or revised Cuba FAQs, with the rules effective September 30. The same package removes more than 100 duplicative subparts and reorganizes delegations, recordkeeping and reporting rules across the sanctions code. Companies with Cuba exposure should treat the cleanup and the policy expansion as separate workstreams: one changes where obligations are found, while the other changes the risk attached to transactions involving Cuba. Law firms should revalidate automated citations, policy links and contract schedules because a formally correct control mapped to an obsolete CFR location can fail operationally even when the substantive prohibition is understood.