The Cuba Leg: Why the Sale Ends at the Florida Port

Why now

Since 30 September a person subject to U.S. jurisdiction may not take part in a direct or indirect financial transaction with any entity on the State Department's Cuba Restricted List [1][2]. Paying a listed company counts. So does passing money through to one.

That rule reaches the last mile of every export: the port.

Every Cuban port is run by a sanctioned operator

• Mariel. The terminal company and the Mariel zone are on the Restricted List [3]. The terminal company and its new operator, Coral Marítima, are on OFAC's SDN list [5][13].
• Havana. The container terminal closed when Mariel opened and is on the Restricted List [3][6]. The general-cargo berths that remain are run by a company of GEMAR, the state port group.
• Santiago, Cienfuegos, Matanzas, Nuevitas. Run by GEMAR companies [6]. GEMAR has been an SDN since 13 July 2026 [4].

The U.S. lines still sailing to Cuba, Crowley and Seaboard Marine, call at Mariel [7].

Why freight terms matter

OFAC's own example: a traveler pays a travel agency, the agency pays a listed hotel, and OFAC treats it as the traveler's direct transaction with the hotel [8]. Freight works the same way. Buy a sea leg that includes Cuban terminal charges and you have paid the terminal.

So the sale ends at the Florida port

For customs clearance, the buyer uses a broker that is not ADESA/ASAT: CIMEX's customs agency is on the Restricted List [3].

Working with founders

Every deal starts the same way: screen every name, from buyer and owners to consignee, forwarder and bank, against the SDN list and the Restricted List. Ask who owns the business; a MIPYME with a state partner is out. Keep state parties out of every role except consignee, and only an unlisted one. Keep records for ten years. The full checklist is in our guide [12].

What's still open

The Restricted List rule applies "except as otherwise authorized" [2]. The export license, §515.533, covers transactions directly incident to a specific authorized export, including transportation [9], and it is not among the licenses OFAC amended to exclude Restricted List dealings [10]. Whether that reaches port charges paid to a GEMAR company or a listed terminal, OFAC has not said. BIS has also suspended License Exception SCP for exports involving deposits into a Cuban-owned bank [11].

Until OFAC answers, we keep it simple: the U.S. side ends in Florida, and the Cuban buyer owns the sea leg. Learn more: How to sell to Cuba’s private sector from Florida · Export route

Not legal advice. Confirm your structure with counsel.