Checklist · Market entry

U.S. Company Cuba Market-Entry Checklist

A pre-entry checklist for U.S. companies considering Cuba: commercial thesis first, then product authorization, counterparty screening, payment reality, and recordkeeping.

Checklist ITA / Trade.gov U.S. exporters OFAC + BIS + State screening

Checklist

  1. Define the exportable product or service.
  2. Identify Cuban buyer, beneficial owner, importer, bank, and logistics provider.
  3. Check OFAC general license / specific license path.
  4. Check BIS export controls.
  5. Screen SDN, CRL, CPAL, GAESA/Gaviota/CIMEX/FINCIMEX exposure.
  6. Validate payment and hard-currency mechanics.
  7. Keep written records of every decision.

Common failure points

  • Assuming private-sector support applies when the importer is state-controlled.
  • Ignoring payment routing and bank de-risking.
  • Treating a Trade.gov opportunity as legal authorization. It is a signal, not permission.

Use Next

Internal tools that make this page actionable.

Cuba country contacts directory Find official counseling contacts once the checklist is mostly complete. Cuba trade barriers tracker Check operational blockers before assuming the market-entry plan can execute. Cuba export compliance checklist Convert market-entry notes into compliance records.

Screen Internally

Cuban Insights checks to run before outreach or shipment.

OFAC Cuba General License Lookup Find the CACR section that could authorize the activity. OFAC Cuba Sanctions Exposure Checker Search names, companies, vessels, aircraft, or aliases against the Cuba SDN list. Cuba Restricted List checker Screen GAESA, Gaviota, CIMEX, FINCIMEX, Habaguanex, and other restricted entities. Public company Cuba exposure check Use when a U.S.-listed counterparty, supplier, bank, or logistics provider is involved.

Official Contacts & Sources

Use these for counseling, authority, and source-of-truth checks.

ITA Trade Americas contact page Use for regional export counseling and Commercial Service routing. ITA Market Intelligence search Use for official U.S. government market notes and sector signals. BIS export controls guidance Use for EAR, ECCN, license, and export-control questions. OFAC Cuba sanctions program Use for CACR, sanctions, general licenses, and Cuba program guidance.

ITA Attribution

This product uses International Trade Administration data and Trade.gov content but is not endorsed or certified by the International Trade Administration.

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