ExecutiveOrdersEO
MemoMemorandumTrump 47 · R Quiet signal

Presidential Memorandum

Reissuance of and Amendments to National Security Presidential Memorandum 5 on Strengthening the Policy of the United States Toward Cuba

This memorandum reissues and amends Trump-era NSPM-5 to tighten U.S. policy toward Cuba, directing agencies to restrict financial transactions with Cuban military-controlled entities, enforce the tourism ban, expand internet access for Cubans, and oppose international efforts to lift the embargo. It sets multiple deadlines for regulatory adjustments and reports while explicitly maintaining the statutory embargo framework.

Federal Register Open PDF 90 FR 38913

Impact dates

  1. State, Treasury, Commerce, Transportation review travel enforcement

  2. Treasury IG report on travel audit implementation

  3. Attorney General report on fugitives from American justice in Cuba

  4. Treasury and Commerce initiate regulatory adjustment process for Cuba transactions

  5. Treasury initiates regulatory adjustment for tourism ban enforcement

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Sectors

AgricultureBanking & financeShipping & logisticsTechnology & softwareOther industrial

Mechanisms

Ban / prohibitionLicensing

Role pressure

  • AdverseImporter — U.S. entities prohibited from direct/indirect financial transactions with GAESA and Cuban military-controlled entities; tightened tourism restrictions reduce permissible travel-related commerce
  • AdverseTrading-partner exporter — Cuba-facing trade constrained by expanded prohibited entity list and reinforced embargo; agricultural commodities/medicines exempt but subject to existing statutory frameworks
  • ProtectiveDomestic producer — U.S. agriculture explicitly supported; statutory exemptions for agricultural commodities, medicines, medical devices preserved under TSRA and Cuban Democracy Act
  • MixedEquipment supplier — Telecommunications/internet access expansion encouraged for Cuban people, but transactions with military-controlled entities prohibited; equipment suppliers face bifurcated market access

Geographies

USOTHER

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

MMM3MGOOGLAlphabetAAPLAppleADMArcher Daniels MidlandBACBank of AmericaBLKBlackRockBGBungeCATCaterpillarLNGCheniere EnergyCTVACortevaDACDanaosDEDeereFCXFreeport-McMoRanGEVGE VernovaGSGoldman SachsHONHoneywellHSBCHSBCQQQInvesco QQQ TrustJPMJPMorgan ChaseMATXMatsonMETAMeta PlatformsMSFTMicrosoftORCLOracleSPYSPDR S&P 500 ETF

Confidence: medium · Policy alerts

Key directives

  • Within 30 days: Treasury and Commerce initiate regulatory adjustment process for Cuba transactions
  • Within 30 days: Treasury initiates regulatory adjustment for tourism ban enforcement
  • State shall identify and publish list of Cuban military/intelligence/security-controlled entities (GAESA, affiliates, subsidiaries, successors)
  • Prohibit direct/indirect financial transactions with listed entities except enumerated exceptions
  • Educational travel must be under U.S. organization auspices with representative accompaniment (except pre-January 27, 2011 permitted travel)
  • Travelers must keep transaction records for 5 years
  • Within 90 days of regulation finalization: State, Treasury, Commerce, Transportation review travel enforcement
  • Treasury shall regularly audit Cuba travel; IG shall inspect and report within 180 days of regulation adjustment and annually thereafter
  • Expand definition of prohibited officials of Cuban Government to include extensive list of officials
  • State and UN Representative shall oppose embargo lift at UN until transition government exists
  • State and Attorney General shall report on transition government requirements under LIBERTAD Act
  • Attorney General shall report on fugitives from U.S. justice in Cuba within 90 days

Who is ordered

Timeline

Immediate

  • Reissuance of NSPM-5 takes effect
  • Statutory embargo remains in force
  • Wet Foot, Dry Foot policy stays terminated

Near term (90d)

  • Treasury and Commerce initiate regulatory adjustments for Cuba transactions (30 days)
  • Treasury initiates tourism ban enforcement regulations (30 days)
  • Attorney General report on fugitives in Cuba due (90 days)
  • State Department identification and publication of GAESA and military-controlled entities list

Long term

  • Annual reporting on U.S.-Cuba engagement begins
  • Treasury Inspector General audits of Cuba travel ongoing
  • Democracy program reviews and internet expansion task force work
  • Potential regulatory finalization and enforcement review at 90 days post-finalization

Risks & tensions

  • Regulatory process initiation deadlines (30 days) do not guarantee finalization timeline, creating implementation uncertainty
  • Broad definition of 'prohibited officials' may create compliance complexity for U.S. entities
  • GAESA entity list publication timing unspecified beyond State Department discretion
  • Tourism ban enforcement may face practical challenges given existing travel categories
  • Task force on internet access lacks specific funding or deadline commitments
Presidential Memorandum: Reissuance of and Amendments to National Security Presidential Memorandum 5 on Strengthening the Policy of the United States Toward Cuba · Executive Orders