State Department Sanctions Cuban State-Owned Bank BICSA; OFAC Issues FAQ 1276

The State Department imposed blocking sanctions against Banco Internacional de Comercio, S.A. (BICSA), a Cuban state-owned bank, under Executive Order 14404. OFAC added the bank to the SDN List and issued FAQ 1276. The FAQ explains that the U.S. government does not intend to target foreign persons for qualifying divestment or wind-down transactions involving BICSA or its majority-owned entities through November 14, 2026. This limited non-targeting posture does not authorize transactions prohibited for persons subject to U.S. jurisdiction under the Cuban Assets Control Regulations or other OFAC authorities.