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Trade and small businesses

· Helfen statt Blockieren editorial team

Sanctions with effects on third parties hit companies that do not want to do anything prohibited. For small businesses the compliance effort is often bigger than the deal.

What is blocked

  • Cuba: Since 2019 more than 10 percent US content by value is enough for goods from third countries to need a US licence1.
  • Cuba: Executive Order 14380 of 29 January 2026 threatens third countries with additional tariffs if they supply oil to Cuba2.

What is expressly allowed

  • EU: The 1996 Blocking Statute protects EU firms from complying with the listed US laws; anyone who must deviate applies to the Commission for an authorisation34.
  • EU: Since 27 December 2023 the Anti-Coercion Instrument, Regulation 2023/2675, has applied. It allows the EU to take countermeasures when a third country puts economic pressure on it or its member states5.

What still does not arrive

  • The Blocking Statute does not open access to the US market. Companies with US business therefore often follow US law. The Court of Justice of the EU allows courts to examine whether the compliance ban places a disproportionate burden on a company6.

Documented examples

  • CubaIn 2024 Cuba exported goods worth 2,128 million US dollars and had a trade deficit of about 5,368 million, according to information given to Douhan7.
  • CubaThe Cuban government puts the embargo’s damage from March 2025 to February 2026 at 8,083.3 million US dollars; the figure comes from its own report and has not been independently verified8.

Counterpoints: why states impose sanctions

  • Cuba: The US government justifies its measures with the policies of the Cuban government. Executive Order 14380 of 29 January 2026 cites support for hostile states and groups and the human rights record2.
  • Business in the US: On 16 June 2017 the US Chamber of Commerce wrote that private sector engagement can be a positive force for change in Cuba9.

Figures marked “according to information given to” are not the cited body’s own measurements but information presented to it.

This page is information, not legal advice. It reports what authorities, courts, governments and organisations decide and say; the views of the side imposing measures and of the side affected stand side by side. “Helfen statt Blockieren” is non-partisan. Please report errors to info@aciel-martinez-poll.com.

Sources

  1. Kelley Drye, “BIS tightens Cuba restrictions, lowers de minimis threshold to 10 percent (Federal Register Doc. 2019-22876)”, 21 Oct 2019. https://www.kelleydrye.com/viewpoints/blogs/trade-and-manufacturing-monitor/bis-tightens-cuba-restrictions-lowers-de-minimis-threshold-to-10-percent
  2. White House, Federal Register 91 FR 5085, “Executive Order 14380: Addressing Threats to the United States by the Government of Cuba (unterzeichnet 29.1.2026)”, 3 Feb 2026. https://www.govinfo.gov/content/pkg/FR-2026-02-03/html/2026-02250.htm
  3. Council of the EU, Regulation (EC) No 2271/96 of 22.11.1996, OJ L 309 of 29.11.1996, S. 1, 22 Nov 1996. https://eur-lex.europa.eu/eli/reg/1996/2271/oj
  4. European Commission, Implementing Regulation (EU) 2018/1101 (criteria for authorisations under Art. 5(2) of Regulation 2271/96), OJ L 199 I, 7.8.2018, 7 Aug 2018. https://eur-lex.europa.eu/eli/reg_impl/2018/1101/oj
  5. European Parliament and Council, Regulation (EU) 2023/2675 of 22.11.2023 on the protection of the Union and its Member States from economic coercion by third countries, OJ L, 2023/2675, 7.12.2023; in force since 27.12.2023, 22 Nov 2023. https://eur-lex.europa.eu/eli/reg/2023/2675/oj
  6. Court of Justice of the EU (Grand Chamber), judgment of 21.12.2021, Bank Melli Iran v Telekom Deutschland, C-124/20, ECLI:EU:C:2021:1035, 21 Dec 2021. https://curia.europa.eu/juris/liste.jsf?num=C-124/20
  7. OHCHR, Special Rapporteur Alena Douhan, Preliminary findings of the visit to Cuba, end of mission statement, 11 to 21 November 2025, 21 Nov 2025. Many figures there are marked “reportedly”, i.e. based on information presented to her. https://www.ecoi.net/en/file/local/2133521/20251121-eom-stm-cuba-sr-negative-impact-unilateral-en.pdf
  8. teleSUR, “Cuba agradece a los 130 países que votaron contra el bloqueo estadounidense en la ONU”, 30 Oct 2026. https://www.telesurtv.net/cuba-agradecepaises-bloqueo-onu/
  9. U.S. Chamber of Commerce, “U.S. Chamber Statement on Administration’s Cuba Policy Announcement”, 16 Jun 2017. https://uschamber.com/international/us-chamber-statement-administration-s-cuba-policy-announcement

All online sources accessed on 3 November 2026.

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