Executive Order of 1 May 2026
In our update of 10 March 2026, we referred to an Executive Order, issued by President Trump on 29 January 2026, which states, amongst others, that Cuba poses “an extraordinary threat to U.S. national security”, and we outlined the decisions taken by our joint venture companies Miramar S.A. and TosCuba S.A. to temporarily suspend operations at one of three hotels in Varadero and considerably decrease the operations of the other group hotels by taking rooms out of operational inventory. That situation remains unchanged.
On 1 May 2026, the U.S. president issued another Executive Order further expanding U.S. sanctions against Cuba, in this instance targeting the activities of foreign entities that invest in or otherwise materially support the government of Cuba.
In its second section the Executive Order defines “Sanctionable Conduct” to include “… any foreign person determined by the Secretary of State, in consultation with the Secretary of Treasury” …. or vice versa, … “that operates or has operated in the energy, defense and related material, metals and mining, financial services, or security sector of the Cuban economy, or any other sector of the Cuban economy, as may be determined by the Secretary of Treasury, in consultation with the Secretary of State…”. The Executive Order also targets entities that have “materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba”. Section four of the Executive Order authorizes the Secretary of State to impose certain sanctions on foreign financial institutions that include investment companies, holding companies and subsidiaries or affiliates thereof. In addition, on 7 May 2026, additional sanctions were imposed on Grupo de Administración Empresarial S.A. (GAESA) under the authority of the most recent Executive Order.
Notwithstanding the fact that neither CEIBA Investments Limited, nor its businesses related to tourism and commercial real estate, have been designated under the Executive Order, there is a risk that such a designation could occur at any time. The Company does not have any assets located in the United States that might be subject to freezing or seizure. However, an expected consequence of the latest Executive Order is that maintaining normal operating relationships with banks, financial institutions and other service providers will become more challenging.
Management and the Board of Directors of the Company are closely monitoring events and consulting with advisors and other stakeholders to assess the potential implications of these actions by the United States government, and will provide further updates if and when required.