The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has added six individuals and five Cuban entities to the Specially Designated Nationals and Blocked Persons (SDN) List. The designated entities include:

• TECNOTEX — machinery and equipment trading
• TECNOIMPORT — wholesale trade and import activities
• Empresa Militar Industrial Yuri Gagarin — military-industrial manufacturing
• DUNA S.A. — vehicle maintenance and related services
• Unión de Industria Militar — military-industrial activities

The entities operate across machinery and equipment trading, vehicle maintenance, wholesale trade, and military-industrial sectors.

OFAC simultaneously clarified that it generally does not intend to target non-U.S. persons under Executive Order 14404 for transactions involving:

• Food and agricultural commodities
• Medicine and medical devices
• Medical-device parts or software updates

This non-targeting statement applies even when an EO 14404-designated party is involved in the transaction. However, OFAC confirmed that any U.S.-person participation must remain within applicable Cuba-related authorizations. The clarification does not eliminate licensing or banking restrictions for U.S. persons.

For companies trading with Cuba: Parties should immediately screen all counterparties, freight agents, wholesalers, and beneficial owners against the new SDN entries. The designated entities span multiple commercial sectors, and indirect exposure through intermediaries is a significant compliance risk.

For humanitarian suppliers: Companies supplying food, medicine, or medical devices to Cuba should document product eligibility and transaction purpose in detail. The non-targeting statement reduces enforcement risk for non-U.S. persons but does not constitute a license or authorization for U.S.-person transactions. Relying on the statement without confirming applicable authorization status creates legal exposure.

For financial institutions: Banks and payment processors should update screening protocols to capture the new designations and review existing correspondent relationships involving Cuban counterparties.

For logistics and freight companies: Freight agents and shipping companies operating Cuba-related routes should verify that none of the newly designated entities appear in their customer or vendor networks.

This update is prepared by ULF NEW YORK for informational purposes only and does not constitute legal advice. Readers should consult qualified counsel regarding specific transactions or compliance obligations.