New Executive Order Threatens Sanctions Against Non-US Persons Doing Business with Cuba, Global Relay Intelligence & Practice

Partners Katelyn Hilferty and Carl Valenstein and associates Eli Rymland-Kelly and Christian Contardo co-authored an article for Global Relay Intelligence & Practice examining a new executive order that significantly expands US sanctions authority related to Cuba, including by authorizing secondary sanctions against non-US persons and foreign financial institutions engaging in certain Cuba-related business activities.

The authors analyze Executive Order 14404 and its implications for companies, financial institutions, and multinational businesses with Cuba touchpoints. The article discusses the order’s broad sanctions criteria, the heightened risks facing non-US financial institutions and counterparties, and the practical impact of new OFAC guidance and general licenses.

Read the full Global Relay Intelligence & Practice article >>

Legal practice assistants Charlie Biggs and Victoria Desimoni contributed to this LawFlash.