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Cuba Country Summary

Medium-High Risk

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Sanctions

Higher Concern

FATF AML Deficient List

Lower Concern

Terrorism

Higher Concern

Corruption

Medium Concern

US State ML Assessment

Medium Concern

Criminal Markets (GI Index)

Medium Concern

EU Tax Blacklist

Lower Concern

Offshore Finance Center

Lower Concern

Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.

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Anti Money Laundering

FATF Status

Cuba is not on the FATF List of Countries that have been identified as having strategic AML deficiencies

Compliance with FATF Recommendations

The latest follow-up Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Cuba was undertaken in 2024. According to that Evaluation, Cuba was deemed Compliant for 19 and Largely Compliant for 20 of the FATF 40 Recommendations. It remains Highly Effective for 0 and Substantially Effective for 5 of the Effectiveness ratings.

Sanctions

The United States maintains the most comprehensive sanctions regime against Cuba, administered primarily by the Office of Foreign Assets Control (OFAC), and implemented through authorities including the Trading with the Enemy Act, the Cuban Assets Control Regulations (CACR), the Cuban Democracy Act, and the Helms-Burton Act, with measures such as asset freezes, a trade embargo, travel restrictions, the Cuba Restricted List, and export controls. Other major actors do not impose autonomous sanctions on Cuba; instead they largely oppose the US embargo and maintain normal relations, with the EU not imposing sanctions on Cuba and using the Blocking Regulation to mitigate extraterritorial US measures, and the UK, Canada, Australia, Japan, New Zealand, and Switzerland likewise not imposing unilateral sanctions.

Criminality

Rating

0 (bad) - 100 (good)
Transparency International Corruption Index 40
World Bank: Control of Corruption Percentile Rank 52

Cuba faces significant challenges related to crime and corruption, characterized by a thriving black market and systemic exploitation in various sectors, including human trafficking and illicit trade. The state's control over resources and the economy, combined with low salaries and currency instability, fosters an environment where corruption is rampant, and public trust in institutions remains low, further complicating efforts to combat these issues.

Economy

Cuba's economy is predominantly state-run and planned, with recent constitutional changes indicating a shift towards increased privatization. The economy heavily relies on tourism, skilled labor exports, and key commodities such as sugar and tobacco, yet it grapples with significant challenges including widespread poverty and shortages of essential goods. While the government has initiated reforms to attract foreign investment, particularly in tourism and agriculture, bureaucratic obstacles and the U.S. embargo continue to hinder substantial economic growth and investment opportunities.

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