The Cuban government has initiated the rollout of Resolution 86/2026, issued by the Ministry of Finance and Prices, across the nation. This regulation mandates that independent entrepreneurs, micro, small and medium-sized enterprises (MSMEs), and other non-state entities report any suspicious activities related to financial crimes and terrorism.
According to a statement by the Ministry on social media, a national training program is underway for officials to ensure the effective enforcement of this measure. These training sessions are conducted in collaboration with local governments and are part of the implementation process for the regulation, which was signed on April 8.
During a session on Saturday, Deputy Minister Yenisley Ortiz Mantecón, alongside the Vice Governor of Havana, conducted training sessions for city officials and administrative council members in the capital as part of this initiative.
Resolution 86 specifies that non-state economic actors engaged in bookkeeping are now designated as "obligated subjects" in the fight against money laundering, terrorism financing, and other illicit activities. Practically, this means they must monitor their clients' transactions, report any suspicions to authorities without notifying the clients, and adhere to strict confidentiality obligations.
The implementation of these training sessions highlights that the measure is now in its operational phase, with compliance being closely overseen by state territorial structures. The involvement of local authorities suggests a tighter grip on the private sector amidst increasing regulatory pressure.
Article four of the resolution stipulates that these entities "are responsible for not providing services to clients listed on international or national lists linked to terrorist activities." Upon detecting a match, they must promptly issue a Suspicious Activity Report (SAR) to the Financial Operations Investigation Directorate (DGIOF) of the Central Bank of Cuba, without informing the client under investigation under any circumstances.
The confidentiality requirement is absolute: private entities "cannot disclose the information contained in the SAR, except upon request from a competent authority," as stated in article 14.
Additionally, they are required to retain all relevant client data for five years after the end of the contractual relationship and must cooperate with authorities when requested.
Failure to comply with these obligations can escalate to the Attorney General's Office, the Ministry of the Interior, and the General Comptroller's Office, as per article 16 of the resolution.
This measure significantly extends state control over the Cuban private sector amid the crisis, which includes over 11,000 registered MSMEs, generating 31.2% of employment and contributing 23% of tax revenue.
This regulation is part of a series of recent measures tightening the conditions for non-state economic activities in Cuba, forcing thousands of entrepreneurs to operate under increased legal and administrative constraints amid a deepening crisis.
Key Aspects of Resolution 86/2026
What is Resolution 86/2026?
Resolution 86/2026 is a regulation issued by the Ministry of Finance and Prices in Cuba that requires non-state economic actors to report suspicious activities related to financial crimes and terrorism.
Who are considered "obligated subjects" under this resolution?
Under Resolution 86, non-state economic actors such as independent entrepreneurs and MSMEs engaged in bookkeeping are considered "obligated subjects" responsible for monitoring and reporting suspicious financial transactions.
What are the confidentiality requirements for private entities?
Private entities are required to maintain strict confidentiality and cannot disclose information contained in Suspicious Activity Reports, except upon request by competent authorities.
What are the consequences of non-compliance with the resolution?
Non-compliance with the obligations under Resolution 86 can result in escalations to the Attorney General's Office, the Ministry of the Interior, and the General Comptroller's Office.