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Cuba Sanctions and OFAC Real Estate Risk visual context
Cuba real estate OFAC sanctions

Cuba Sanctions and OFAC Real Estate Risk

OFAC and Cuba Restricted List risk for buyers, brokers, developers, operators, and U.S.-linked investors.

Answer first

For U.S. persons and U.S.-linked structures, Cuba real estate is a sanctions analysis before it is a property search.

This brief is designed for foreign buyers who need a realistic Cuba property filter before they compare locations, asset types, partners, or deal structures.

Best-fit buyer profile

U.S. personsPayment planningHotel screeningCounterparty diligence

Market notes

  • OFAC regulations and the Cuba Restricted List can prohibit direct financial transactions.
  • Non-U.S. investors still need to understand banking, counterparties, and secondary exposure.
  • Hotel and tourism counterparties require extra scrutiny because several entities are listed.

Due-diligence checklist

  • Identify every bank, seller, operator, manager, broker, and state-linked counterparty.
  • Check OFAC, SDN, and Cuba Restricted List status before funds move.
  • Use qualified sanctions counsel where U.S. jurisdiction may apply.
Sources

Why this page is source-backed

Each brief keeps the evidence visible: concise answer, current statistics where available, and primary or high-authority sources.

U.S. Treasury OFAC: Cuba sanctions

U.S. persons and U.S.-linked entities must verify whether a Cuba transaction is prohibited, exempt, generally licensed, or specifically licensed.

Open source

Federal Register notice: Cuba Restricted List update

Direct financial transactions with listed Cuba Restricted List entities are generally prohibited under the Cuban Assets Control Regulations.

Open source

U.S. State Department: Cuba Travel Advisory

The May 7, 2025 advisory lists Cuba at Level 2 and highlights crime, unreliable electrical power, and OFAC travel restrictions for U.S. persons.

Open source

UNCTAD Investment Policy Hub: Cuba Foreign Investment Act, Law No. 118

Law No. 118 permits approved foreign investment structures, including real estate for private, tourist, office, and tourism-development purposes.

Open source
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