Cuban Regime Forces Private Sector to Secretly Report Clients on Terrorism Lists

On Wednesday, the Cuban regime unveiled Resolution 86/2026 in Official Gazette No. 37, a decree from the Ministry of Finance and Prices. This resolution mandates that self-employed individuals, micro, small, and medium-sized enterprises (MSMEs), non-agricultural cooperatives, and local development projects act as financial surveillance agents for the state. They are now required to verify if their clients appear on terrorism lists and report them discreetly to the authorities.

Signed on April 8 by Minister Vladimir Regueiro Ale, the directive identifies all non-state economic actors involved in bookkeeping as “obligated subjects,” compelling them to scrutinize the financial dealings of private businesses.

Financial Surveillance Obligations

According to article four of the resolution, these entities “must not provide services to clients listed on international or the National List of persons and entities associated with terrorist activities.”

If they detect a match, they must promptly issue a Suspicious Activity Report (SAR) to the General Directorate of Financial Operations Investigation (DGIOF) at the Central Bank of Cuba, without notifying the client under scrutiny.

The confidentiality requirement is stringent: private entities “cannot disclose the information contained in the SAR, except upon request from a competent authority,” as stipulated in article 14.

Record-Keeping and Compliance

Additionally, they are required to maintain all pertinent client data for five years following the end of the contractual relationship and must cooperate with authorities whenever demanded.

Failure to comply with these obligations can escalate to the Office of the Attorney General, the Ministry of the Interior, and the General Comptroller's Office, as detailed in article 16 of the resolution.

Expanding State Control Over Private Sector

This measure significantly broadens the state's control over Cuba's private sector amid the ongoing crisis, which includes over 11,000 registered MSMEs, generating 31.2% of employment and contributing 23% of fiscal revenue.

The resolution follows an unprecedented regulatory crackdown: Resolution 56/2024 revoked wholesale trade licenses for self-employed individuals, MSMEs, and cooperatives; Decree-Law 91/2024 imposed fines of up to 72,000 pesos for violations; and 2026 saw the introduction of mandatory electronic invoicing and currency usage restrictions in commerce.

Targeting Exiled Cubans

Perhaps the most telling aspect of the resolution is the list that private entities are mandated to consult before offering any service: the Cuban regime's National Terrorist List, updated in July 2025 via Resolution 13/2025 by the Ministry of the Interior. This list includes 62 individuals and 20 entities, primarily Cuban exiles residing in Florida.

Among those listed are media personality Alex Otaola, activist Eliecer Ávila, the Cuban Paparazzi, and organizations like Alpha-66 and the Cuban American National Foundation, all of whom the regime has labeled as terrorists since the list's initial release in December 2023.

The government defends this measure as part of its Economic and Social Program Objective No. 8 — “to advance the implementation of general directives aimed at preventing and reducing crime, corruption, illegal activities, and social indiscipline” — and as a response to commitments with the Latin American Financial Action Task Force (GAFILAT), which identified that Cuba's non-state sector was not integrated into the suspicious activity reporting system.

In practice, Resolution 86/2026 does more than impose additional bureaucratic burdens on entrepreneurs already operating under extreme conditions: it effectively transforms them into extensions of the state’s control apparatus, forcing them to surveil their own clients and report them secretly to the same authorities that oppress them.