The United States expands sanctions against Cuba at a critical moment for Havana

The so-called package of 176 measures you refer to corresponds to the “Economic and Social Program for 2026”, a broad plan of economic reforms promoted by the Government of Miguel Díaz‑Canel. According to information available up to August 2026, the program has already been endorsed by the Central Committee/Politburo of the Communist Party and approved by the National Assembly of People's Power, but its implementation is in an initial and gradual phase.

Current status of the processing

Based on information gathered by the newspaper Demócrata:

• President Díaz‑Canel first announced a package of structural reforms under the label “Economic and Social Program for 2026”, inspired by the models of China and Vietnam, with the objective of partially liberalizing the economy and cushioning the impact of U.S. sanctions (Demócrata, 06-13-2026).
• At that time, it was indicated that the measures still needed to receive approval from the Politburo and the National Assembly and that, after that endorsement, a “informative and explanatory process” aimed at the public would be activated.
• Shortly after, the plan was specified as a package of 176 measures which, according to Demócrata, 06-19-2026, was endorsed by the Communist Party on the 17th and approved by the National Assembly of People's Power on the 18th. That piece already describes it as a program formally adopted by the island's highest legislative body.

Therefore, on the political-institutional level, the main processing is completed: the package is approved as the official economic roadmap for 2026 and subsequent years. What remains open is not its approval, but the normative, administrative, and practical execution of the 176 measures.

What the 176 measures cover

The consulted texts do not offer a detailed list, but do provide some key axes of the package:

• Reordering of the economic model around six major axes, including tourism, agriculture, foreign trade, and real estate development (Demócrata, 06-19-2026).
• Opening to the private sector and the possibility of transforming state-owned companies into commercial companies with private participation.
• Partial liberalization of the financial system, including the entry of private banks and greater scope to operate with foreign currency.
• Greater prominence of new actors in tourism and progressive elimination of the state monopoly on imports and exports (Demócrata, 06-12-2026).
• Reform of the subsidy system and gradual dismantling of the ration book, compensated by more targeted social protection schemes.
• Reduction and reorganization of ministries (from 27 to 21) to simplify the administrative structure.

Next steps for implementation

Based on what has been published, several blocks of “next steps” anticipated by the Cuban leadership itself can be identified:

• Normative and regulatory deployment: many of the 176 measures require decrees, resolutions, and changes in sectoral regulations (state companies, banking, tourism, foreign trade, subsidies, labor market, etc.). A piece-by-piece schedule is not yet detailed, but the plan is presented as a multi-year structural reform.
• “Informative and explanatory process” for the population: even before parliamentary approval, Díaz‑Canel announced a public education phase to explain the content and scope of the program (Demócrata, 06-13-2026). This process is key, especially in the face of sensitive changes such as regulated price increases or the reduction of generalized subsidies.
• Institutional reorganization: the reduction in the number of ministries and the new distribution of administrative competencies is a prerequisite for certain measures (for example, greater business autonomy or opening to foreign capital) to be applied in a coordinated manner.
• Gradual application in priority sectors: the Cuban press itself and analyses collected by Demócrata emphasize that the immediate focus is on tourism, energy, foreign trade, and domestic production, heavily affected by the fuel crisis and sanctions. It is reasonable to expect that the first practical provisions of the package will concentrate on these areas.
• Interaction with the international context: the package arises amid a tightening of U.S. sanctions. Several recent reports on Cuba at the United Nations and the EU highlight that the economic viability of the plan will also depend on whether that coercive external environment is maintained, worsened, or relaxed.

Limitations of the available information

None of the sources consulted to date detail a traffic light system for execution measure by measure nor an official implementation schedule for the 176 actions. The picture they offer is of a program already politically approved, which has begun its normative development and public explanation phase, but whose concrete deployment will necessarily be staggered and dependent both on internal administrative capacity and the international environment.

Based on research conducted in databases and press accessible from Spain, no Cuban normative text (decree, law, statutes published in the Official Gazette, internal regulations, etc.) has been found that explicitly and verifiably details the legal competencies and powers of the president of the Cuban Institute of Friendship with the Peoples (ICAP). The references found to ICAP are political or geopolitical in nature (for example, in news about U.S. sanctions or the characterization of ICAP as an influence network), but do not include the internal Cuban legal framework nor the content of its statutes.

This has an important methodological consequence: without access to the ICAP's founding text or its current statutes, it is not possible to rigorously enumerate, article by article, the president's functions, the method of appointment, powers of management, signature, representation or internal supervision, nor what powers are delegated by the Council of Ministers, the Communist Party of Cuba, or the governing bodies of the Institute itself.

What can be cautiously inferred

Although we do not have the specific articles, based on the nature of ICAP as a Cuban state entity dedicated to relations of solidarity and friendship with other peoples, it can be assumed — in a generic and non-binding way — that the president:

• Holds the institutional representation of ICAP before other Cuban State bodies, parties, and mass organizations, as well as before foreign organizations and international solidarity movements.
• Directs the activity and political line of the organization, in coordination with the leadership of the State and the Communist Party of Cuba, setting priorities in matters of friendship relations, international campaigns, solidarity brigades, etc.
• Supervises the internal structure (directorates, departments, delegations) and, presumably, proposes or validates appointments at the Institute's management levels, according to mechanisms established by its internal rules and the Cuban administrative system.
• Acts as the principal signatory of agreements, declarations, cooperation programs, and collaboration agreements of ICAP with associations, parties, unions, or other foreign actors, always within the margins set by the Cuban Government.
• Reports to higher political bodies on the fulfillment of ICAP's annual plans, the use of its resources, and the results of its influence and solidarity activities.

However, all the above is a functional reconstruction based on how analogous organizations are structured in other countries and the logic of the Cuban system itself; it does not equate to citing Cuban legislation nor replaces direct consultation of official texts.

Where to find the strict legal answer

To know exactly the legal competencies and powers of the ICAP president according to Cuban law, it would be necessary to access:

• The founding norm of the Institute (probably a decree or decree-law published in the Official Gazette of the Republic of Cuba), where the legal nature of the organization, its objectives, and governing bodies are usually defined.
• The statutes or other internal regulations of ICAP, which normally detail:
  • the composition of governing bodies;
  • the specific functions of the presidency;
  • the appointment and dismissal mechanisms;
  • the regime of delegation of signature and representation;
  • hierarchical relations with the rest of the Cuban administration.
• Possible subsequent reforms (new decrees, resolutions, or agreements of the Cuban Council of Ministers) that have modified the structure and competencies of ICAP or its presidency.

The most reliable way to obtain these documents is to consult directly:

• The search engine of the Official Gazette of the Republic of Cuba, filtering by “Instituto Cubano de Amistad con los Pueblos” or “ICAP”.
• The institutional website of ICAP itself, where, if it meets usual standards, it could host its legal basis, statutes, or at least references to the founding norm.
• Academic compilations or manuals of Cuban public law on administrative organization, which sometimes reproduce or synthesize the regulations of the main state bodies.

Since the sources consulted in this research do not include those texts nor offer a reliable summary of them, any attempt to detail precisely the legal powers of the ICAP presidency (for example, stating that it can issue certain types of resolutions, approve binding plans, or intervene in specific matters) would be speculative and legally imprecise. For academic or professional work, it is essential to directly verify the primary Cuban regulations before concluding.

In summary, it is known that ICAP is considered by various international actors as a relevant body of the Cuban state apparatus and that its president occupies a central position in that structure; but the exact description of its legal competencies and powers can only be made with support from the Official Gazette and the Institute's internal statutes, which are not found in the databases used here.

There is no single “international permit” that authorizes a foreign company to operate with Cuban entities sanctioned by the United States; the real framework is a mosaic of U.S. sanctions (OFAC), internal regulations of other countries (such as the EU Blocking Statute), and United Nations recommendations. Based on the information available in the cited sources (Demócrata, BOE, official EU website, union and government statements), a series of minimum requirements and precautions can be extracted to reduce legal risk.

1. Precise identification of the Cuban counterparty

The first practical requirement is to determine whether the Cuban entity is formally sanctioned by the United States or included in already designated structures:

• Recent sanctions are focusing on the military conglomerate GAESA and its subsidiaries, as well as mining, energy, financial, and defense companies (for example, the mining company La Victoria, Moa Nickel, the International Financial Bank, or logistics and steel companies), according to several news reports from Demócrata.
• The Office of Foreign Assets Control (OFAC) also applies the 50% control criterion: in other sanctions (Iran, Venezuela) it is specified that assets or companies controlled 50% or more by sanctioned subjects are also affected, and third parties providing “certain services” are warned of risk (example in Iran/Venezuela). Although the text refers to other countries, it illustrates the general logic of sanction lists.

Therefore, a starting requirement: check if the Cuban entity appears on OFAC lists or is controlled by already designated structures (e.g., GAESA, ministries, armed forces).

2. Fit the operation within OFAC licensing regimes

In some cases, OFAC itself opens operational windows through licenses:

• For Cuba, a “favorable” policy of granting specific licenses for the resale of Venezuelan oil has been announced, provided that operations benefit “the Cuban people” and the private sector and do not involve or benefit Cuban armed forces, intelligence services, or state entities (U.S. Treasury guide).
• The Treasury itself clarifies that those applying for these licenses do not need to be incorporated in U.S. territory, implying that foreign companies can request them if their operation falls within the authorizable category.

From this it follows that if the operation directly or indirectly involves Cuban entities under sanction or strategic sectors (energy, mining, defense, security), the foreign company will normally have to obtain an OFAC license or demonstrate that it clearly falls within an exempt category (for example, certain humanitarian purposes or support for the private sector not linked to the State).

3. Risk of secondary sanctions and Executive Order 14404

Demócrata sources indicate that Executive Order 14404 expands Washington's scope of action against companies operating with sectors considered strategic for the Cuban Government, even allowing freezing assets in U.S. territory of foreign companies that collaborate with activities in energy, mining, defense, or security on the island (Spanish companies leave Cuba).

Additionally, in other sanction regimes (Iran) OFAC explicitly refers to the possibility of secondary sanctions on banks or companies from third countries that provide certain services to sanctioned parties. Although the cited texts do not formulate this only for Cuba, they show that:

• The foreign company must assume that there is a risk of sanction even without the classic “U.S. nexus” if it is considered to significantly assist sanctioned subjects.
• The risk level is especially high when the counterparty belongs to the Cuban military-state network.

4. International and European regulations: Blocking Statute

From the international perspective, the United Nations and numerous actors (including CCOO in Spain) have been qualifying the blockade and U.S. unilateral lists as measures with extraterritorial effect contrary to international law, and call for their lifting (CCOO note).

In the European Union, Regulation (EC) No. 2271/1996, known as the Blocking Statute, has been used to protect European operators against the extraterritorial application of third-country sanctions. The Spanish Government has recently requested the Commission to activate it against U.S. sanctions in other contexts, emphasizing that it allows “nullifying third-country rules that affect EU interests” (Moncloa activity).

This means that, for EU companies, there is also a framework that discourages automatically submitting to U.S. extraterritorial sanctions; but in practice they must balance that protection with the real risk of economic retaliation from the United States.

5. Minimum operational compliance requirements

In light of all the above, a foreign company intending to operate with sanctioned or high-risk Cuban entities should, at a minimum:

• Conduct enhanced due diligence on the counterparty (ownership, control, links to GAESA, ministries or armed forces, inclusion in OFAC lists).
• Analyze whether the operation fits within any general license or specific licensing policy of the U.S. Treasury for Cuba (such as those related to Venezuelan oil for the private sector), and apply for the license if appropriate.
• Evaluate the company's exposure to the U.S. financial system and market (assets, use of dollars, correspondent banks, subsidiaries), since Executive Order 14404 allows freezing third-party assets.
• Check compliance with the regulations of its own State (for example, Blocking Statute in the EU) and possible conflicts between obeying OFAC or its domestic law.
• Include contractual clauses on sanctions and termination that allow cutting the relationship if the sanction regime tightens.
• Seek specialized legal advice on international sanctions before closing any significant volume operation.

In summary, the legality of these operations is not defined by a single “international requirement”, but by the degree of simultaneous compliance with U.S. regulations, the company's State regulations, and general international law obligations, in a highly changing political environment.