ExecutiveOrdersEO
Det 2025-11DeterminationTrump 47 · R

Presidential Determination 2025-11

Continuation of the Exercise of Certain Authorities Under the Trading With the Enemy Act

This determination extends for one year the President's authority under the Trading With the Enemy Act (TWEA) to maintain economic sanctions against Cuba through the Cuban Assets Control Regulations. The continuation maintains the long-standing embargo framework without policy changes.

Federal Register Open PDF 90 FR 42795

Impact dates

  1. In 25d

    Extended TWEA authorities expire unless renewed

Market exposure

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

Sectors

Banking & financeAgricultureOil & gasShipping & logistics

Mechanisms

Ban / prohibitionLicensing

Role pressure

  • AdverseTrading-partner exporter — Cuban state entities and third-country exporters to Cuba face continued blocked access to US markets and dollar financing
  • MixedDomestic producer — US agricultural and medical exporters retain limited licensed opportunities but face persistent restrictions; most US firms remain excluded
  • AdverseDownstream manufacturer — Non-US companies with Cuba ties risk US secondary sanctions and denial of US market access

Geographies

USEUCAOTHER

Exposure dates

  • — Extended TWEA authorities expire unless renewed

Illustrative public companies

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

ADMArcher Daniels MidlandBACBank of AmericaBLKBlackRockBGBungeCATCaterpillarLNGCheniere EnergyCVXChevronCOPConocoPhillipsCTVACortevaDACDanaosXOMExxon MobilFDXFedExGEVGE VernovaGSGoldman SachsHSBCHSBCJPMJPMorgan ChaseMATXMatsonSHELShellSPYSPDR S&P 500 ETFTSLATeslaTSNTyson FoodsUPSUPSZTOZTO Express

Confidence: high · Policy alerts

Key directives

  • Continue exercise of TWEA authorities with respect to Cuba for 1 year until September 14, 2026
  • Secretary of the Treasury to publish this determination in the Federal Register

Who is ordered

Timeline

Immediate

  • Determination takes effect upon signing; Treasury Secretary directed to publish in Federal Register

Near term (90d)

  • Federal Register publication expected by early September 2025

Long term

  • Sanctions authorities remain in force through September 14, 2026; next continuation determination required before that date to avoid lapse

Risks & tensions

  • Perpetuates six-decade embargo without policy recalibration despite evolving regional dynamics
  • Annual renewal mechanism creates procedural risk of inadvertent lapse if future determination delayed
  • Maintains extraterritorial reach that generates friction with EU and other trading partners
Presidential Determination 2025-11: Continuation of the Exercise of Certain Authorities Under the Trading With the Enemy Act · Executive Orders