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Calling the emergency contact number provides a quick and effective way to speak directly to a duty Shipowners’ claims handler in the event of an incident or casualty involving an entered vessel.

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Correspondents

Emergency Contact

1 Jul 2026

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Executive Order 14404, issued by the White House on 1 May 2026, opens a new chapter in US Cuba policy. The Order sits in parallel with the long-standing Cuban Assets Control Regulations and now allows OFAC to designate foreign owners, operators, charterers, brokers and their banks even absent any US link.

A material shift in posture

Until now, US Cuba sanctions have mainly applied to US persons. Foreign companies could still trade with Cuba subject to specific limits (such as the CACR’s 180-day rule, which keeps vessels that have carried cargo to or from Cuba out of US ports for six months) but without broad secondary-sanctions risk. EO 14404 changes that by bringing the sanctions regime closer in shape to those the US already runs against Russia, Iran and Venezuela, drawing into focus the dominant US-dollar financial system.

What has changed

Under EO 14404, OFAC may freeze the US-side property of any foreign person identified as active in one of five named sectors of the Cuban economy (energy, defence and related materiel, metals and mining, financial services, and security) or as supporting the Cuban Government or a blocked person. Foreign Financial Institutions, a term the Treasury reads broadly enough to include insurers, are separately exposed to secondary sanctions for facilitating significant transactions with designated parties. The “material assistance” limb extends through counterparty chains: support given at a remove is enough to trigger enforcement.

The first designations followed within days. On 7 May the State Department added Grupo de Administración Empresarial S.A. (GAESA: Cuba’s armed-forces holding company, with subsidiaries across ports, logistics, retail and tourism), a senior GAESA officer (Ania Guillermina Lastres Morera) and Moa Nickel SA. OFAC published General License No. 1 the same day, preserving CACR-authorised transactions, with explanatory FAQs. FAQ 1254 sets a grace period to 5 June 2026 for wind-down transactions involving GAESA; FAQ 1256 confirms that operating in a listed sector is not in itself an automatic trigger. The scope of relevant sectors has yet to be detailed, which adds further uncertainty.

What Members should do

Review all Cuba-touching fixtures, port and marina calls, bunkering and counterparties for exposure to GAESA, Moa Nickel SA or any other SDN-listed party such as Gaviota and Almacenes Universales. Any exposed activities are no longer afforded protection under the wind down period, which expired on 5 June 2026.

Refresh sanctions screening and scrutinise ownership: an existing SDN may now carry EO 14404 as a designation authority, materially changing the secondary-sanctions risk on a longstanding trading relationship even if no new entity appears on the list.

Check whether cargo, voyage or counterparty touches any of the five listed sectors, and stay alert to indirect exposure through charterers, receivers, brokers, bunker suppliers or paying banks – as “material assistance” captures indirect as well as direct support.

Confirm that sanctions clauses in charterparties, BIMCO terms, financing and bunker contracts permit withdrawal or pause if an EO such as EO 14404 is engaged, and that existing wording captures secondary-sanctions risk to non-US parties.

Consult sanctions counsel where any fixture, voyage or commitment is in doubt, particularly where US persons (crew, beneficial owners, charterers, brokers, paying banks) are involved, or where cargo or counterparty touches the five targeted sectors.

Cover

Cover is not available under the Club’s Rules for any trade, voyage or transaction in breach of applicable sanctions. Where US reinsurance applies, the Club may also be unable to reimburse Members for sums unrecoverable from its reinsurers.

Conclusion

Cuba trades are no longer low risk for non-US shipping interests. Sanctions are not automatic, but the possibility of designation and the reach of the “material assistance” limb call for greater caution and tighter due diligence. Further designations and clarifications are expected, and the Club will continue to update Members as the position develops. If you are uncertain whether a proposed fixture, cargo, port call, marina visit or counterparty may engage EO 14404 or the CACR, legal advice from sanctions lawyers is recommended.

Members are reminded that this general update is for information purposes only and does not constitute as providing legal advice.

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