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 Penalty": Understanding the risk of losing U.S. correspondent account access under the new secondary sanctions authorities.E.O. 14024 vs. The Cuba EO: Why the U.S. is mirroring the Russian Harmful Foreign Activities framework.Compliance Red Flags: New triggers for human rights abuses and public corruption.Operational Checklist: Immediate steps for KYC updates and screening for "Adult Family Members" of designated persons.

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