What it captures
Three actions covering the May-2024 → May-2026 reversal in US Cuba sanctions posture:
- 2024-05-29 OFAC CACR amendments — final rule implementing the
May 2022 Biden policy: reinstated U-turn general license, broadened "independent private sector entrepreneur" definition to MIPYMEs up to 100 employees, authorised Cuban-resident private-sector accounts at US banks, expanded internet-services authorisations.
- 2026-01-29 EO 14380 — IEEPA national emergency w.r.t. Cuba;
secondary-tariff authority targeting third-country suppliers of crude oil and petroleum products to Cuba.
- 2026-05-01 EO 14404 — sectoral blocking sanctions on Cuba's
military-controlled tourism conglomerates (GAESA, Gaviota) and remittance/financial conduits.
Why it's a distinct theme
The post-2024-us-trade-reset theme captures the broader 2025-26 emergency-authority tariff cluster (Trump-era IEEPA usage, DPA §303 energy-security determinations). The Cuba arc straddles that theme but extends earlier: it begins with a Biden-era easing rule in May 2024 that the 2026 Cuba EOs effectively neutralise without formally rescinding. Keeping the lineage as a dedicated thread preserves the policy-reversal narrative that is lost when the 2024 easing is filed alone in sanctions-enforcement-civil-penalties (wrong category — that theme is for penalty-driven enforcement actions, not regime amendments) or in the post-2024-us-trade-reset cluster (wrong period — the 2024 easing predates the trade-reset).