Not legal, tax, or investment advice — and not authorization for any transaction. U.S. sanctions (the Cuban Assets Control Regulations, 31 CFR Part 515) heavily restrict — and in most cases prohibit — dealings between U.S. persons and Cuba, including any form of investment or equity in a Cuban business. The rules are complex, fact-specific, and change; nothing on this site is a determination that any transaction is lawful. Structure anything Cuba-facing only with qualified OFAC sanctions counsel, and screen every party (names, entities, wallets) with QvaPay Sentinel.
Primary sources: OFAC Cuba Sanctions · 31 CFR Part 515 (CACR) · OFAC Cuba FAQs · Cuba Restricted List
Confiscated property & the claims map
Helms-Burton Title III lets U.S. nationals sue anyone "trafficking" in property confiscated by the Cuban government after 1959 — for treble damages (Title III suits have been allowed since 2019). Title IV adds visa bars. Any investor touching a confiscated asset inherits that liability. These are the landmines under the atlas.
Every confiscated asset in the atlas — original owner, certified 1972 value, current claim-holder, Title III status.
The Title III suits against four cruise lines that show what trafficking liability looks like.
The five gates of a Title III suit — certification, the 1996 ownership cutoff, the 2-year clock.
The claims table
Every confiscated asset in the atlas, sorted by Title III exposure.
| Asset | Original owner (1960) | 1972 value | Current claim-holder | Certified | Title III |
|---|---|---|---|---|---|
| Arechabala Distillery / Havana Club origin Rum | José Arechabala S.A. | uncertified; sold to Bacardi | Bacardi (rights) | — | ⚠️ Active |
| Belot Oil Refinery (Esso/Exxon) Energy & power plants | ExxonMobil (Standard Oil/Esso) | $71.6M | ExxonMobil | Certified | ⚠️ Active |
| Partagás Cigar Factory (Cifuentes) Cigars | Cifuentes family | uncertified | Habanos S.A. (Cuban) / General Cigar (non-Cuban, DR) | — | ⚠️ Active |
| Port of Santiago de Cuba (Guillermón Moncada) Ports | Javier García-Bengochea (Santiago port interest) | uncertified | García-Bengochea family | — | ⚠️ Active |
| Bacardí Original Distillery (Ronera Santiago) Rum | Bacardí family | uncertified (family fled) | Bacardi Limited (Bermuda) | — | ⚠️ Potential |
| Edificio Bacardí (Bacardi Building) Rum | Bacardí family | uncertified | Bacardi Limited | — | ⚠️ Potential |
| H. Upmann Factory / Montecristo (Menéndez-García) Cigars | Menéndez & García family | uncertified | Habanos S.A. (Cuban) / Altadis USA, La Romana DR (non-Cuban) | — | ⚠️ Potential |
| Hoyo de Monterrey / Punch (Palicio) Cigars | Palicio family | uncertified | Habanos S.A. (Cuban) / General Cigar, Honduras (non-Cuban) | — | ⚠️ Potential |
| Romeo y Julieta Cigar Factory Cigars | Rodríguez lineage | uncertified | Habanos S.A. (Cuban) / Altadis USA, DR (non-Cuban) | — | ⚠️ Potential |
| Textilera Ariguanabo (Bauta) Manufacturing | Dayton Hedges (US) | built by US capital 1931 | state | — | Review |
| Coca-Cola Bottling (Havana) Manufacturing | The Coca-Cola Company | $27.5M | The Coca-Cola Company | Certified | None active |
| Colgate-Palmolive Factory (Havana) Manufacturing | Colgate-Palmolive | $14.5M | Colgate-Palmolive | Certified | None active |
| Cuban Electric Company (national grid) Energy & power plants | Cuban Electric Company | $267.6M | Office Depot, Inc. | Certified | None active |
| Cuban Telephone Co. (ITT) Telecom | ITT (as trustee) | $130.7M+ | Marriott International (via Starwood) | Certified | None active |
| El Encanto Department Store Retail | Solís/Entrialgo families | uncertified | site (Parque Fe del Valle) | — | None active |
| Hotel Nacional / Habana Riviera Tourism | various (incl. Lansky estate, Riviera) | uncertified | heirs | — | None active |
| Moa Nickel + Cobalt Belt Mining | Moa Bay Mining Co. (Freeport Sulphur) | $88.3M | Freeport lineage | Certified | None active |
| Nicaro Nickel Plant ('René Ramos Latour') Mining | Nicaro Nickel Co. | $33.0M | original claimant | Certified | None active |
| Port of Moa Ports | Moa Bay Mining Co. (Freeport Sulphur) | $88.3M | Freeport lineage | Certified | None active |
| Texaco Refinery (Santiago) Energy & power plants | Texaco Inc. | $50.1M | Chevron | Certified | None active |
| United Fruit Sugar (Boston & Preston mills) Agriculture | United Fruit Sugar Co. | $85.1M | Chiquita lineage | Certified | None active |
Certified values are the U.S. Foreign Claims Settlement Commission (FCSC) 1972 figures; statutory interest makes present values far higher. Uncertified claims may still support Title III suits. Not legal advice.
Havana Docks — the landmark case
What Title III trafficking liability looks like in practice.
Havana Docks v. the cruise lines
Havana Docks has pursued Title III claims against Carnival, Royal Caribbean, Norwegian and MSC for using the confiscated Havana cruise terminal. The case is a leading example of the trafficking liability U.S. companies face when they use confiscated Cuban property — one of the clearest reasons U.S. capital cannot touch Cuba's confiscated infrastructure, and why this overlay exists.
How to pursue a Helms-Burton claim
A reality check first: the U.S. Foreign Claims Settlement Commission (FCSC) certified 5,913 Cuban claims across two programs (completed 1972 and 2006), and both are closed. As of 2026 there is no open program to certify a new claim. But certification is not required to sue under Title III — here is how to tell where you stand.
- 1 · Check whether you already hold a certified claim
Search the FCSC's published Cuba decisions and list of certified claims. A certified claim is conclusive proof that you own it — a major evidentiary advantage in court. FCSC — Claims Against Cuba ↗
- 2 · Confirm you can bring a Title III suit
You must be a U.S. national who owns the claim; the property must have been confiscated by the Cuban government on or after Jan 1, 1959; and the claim must be worth more than $50,000 (excluding interest, costs, and fees — the trebled damages don't count toward that threshold). This applies to certified and uncertified claims alike.
- 3 · Mind the March 12, 1996 ownership cutoff — the hard gate
For property confiscated before March 12, 1996 — essentially all Cuba claims — you must have acquired the claim before that date. Heirs who inherited after it are barred — even if the property was taken decades earlier — the rule that has sunk most Title III cases. You need not have been a U.S. national at the moment of the taking: an émigré who later naturalized and owned the claim before that date can qualify.
- 4 · Watch the 2-year clock
A Title III action must be filed within 2 years after the "trafficking" stops. Courts treat this as a statute of repose (no tolling), though new or ongoing trafficking can restart the clock.
- 5 · Get qualified counsel
These suits are complex and most have failed on the ownership cutoff or on proving "trafficking." Work with experienced OFAC / Helms-Burton counsel — the atlas lists leading U.S. sanctions attorneys. See OFAC counsel →
Informational summary of the LIBERTAD Act (22 U.S.C. §6082–6084); figures from the U.S. Foreign Claims Settlement Commission. Not legal advice — consult qualified counsel before acting.
Eight Cuban dynasties whose property was confiscated in 1960 — Bacardí, Arechabala, Fanjul, Lobo, Cifuentes, Menéndez, Mas Canosa and Mestre. Not all hold Helms-Burton claims (some weren't eligible; Mas Canosa authored the law) — but each is a story of what was taken, and what they rebuilt.
Common questions
What is Helms-Burton Title III?+
The provision of the 1996 LIBERTAD (Helms-Burton) Act that lets U.S. nationals sue anyone who “traffics” in property the Cuban government confiscated after 1959.
Who can sue, and how do I know if I have a certified Cuba claim?+
To sue under Title III you must be a U.S. national who owned the claim before March 12, 1996 (the cutoff applies to property confiscated before that date), over property Cuba confiscated after 1959, worth more than $50,000. An FCSC-certified claim (about 5,900 exist) is conclusive proof you own it, but certification isn't itself required — and both FCSC certification programs are now closed.
How do I make a Helms-Burton claim — can I get a new claim certified?+
You can't newly certify a claim: the FCSC's two Cuban Claims Programs closed in 1972 and 2006 and none is open today. But you may still bring a Title III lawsuit if you're a U.S. national who owned the claim before March 12, 1996 (for property confiscated before that date) and it exceeds $50,000. Start by checking the FCSC list to see if you already hold a certified claim, then consult OFAC / Helms-Burton counsel.
What was confiscated in Cuba after 1959, and who holds the claim now?+
Ports, refineries, sugar mills, hotels, utilities, and brands. The atlas maps the largest certified claims to today's holders — the Cuban Electric Company claim (~$267.6M) is held by Office Depot, and ITT's (~$181.8M) by Marriott.