Cuba & Title III

BICSA designated under E.O. 14404; wind-down window for foreign persons runs to 14 November

BICSA was designated under E.O. 14404 on 15 October; FAQ 1276 gives foreign persons until 14 November to wind down. Title III: two Supreme Court rulings in 2026.

Sovereign Creditor Review Staff

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Status: Primary source · Date: 15 October 2026 · Country: Cuba & Title III · Topic: Sanctions & licences

On 15 October the State Department designated Banco Internacional de Comercio, S.A. (BICSA) under E.O. 14404. OFAC FAQ 1276 says the U.S. does not intend to target foreign persons, including foreign financial institutions, for transactions ordinarily incident and necessary to divest or wind down BICSA-related dealings through 14 November 2026. Persons subject to U.S. jurisdiction remain prohibited from BICSA transactions absent OFAC authorisation.

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