President Trump Revives His Hardline Cuba Policy

On June 30, 2025, President Donald Trump formally reissued National Security Presidential Memorandum 5 (NSPM-5), Strengthening the Policy of the United States Toward Cuba, which renews the Cuba policy framework established during President Trump’s first term. Although this action is primarily a reaffirmation of the previous policy, it is still the most significant development in US policy toward Cuba since Inauguration Day, when President Trump quickly reversed President Biden’s brief easing of certain restrictions on Cuba.

The 2025 NSPM-5 echoes much of the original 2017 memorandum. In particular, the new memorandum reiterates the administration’s commitment to supporting the embargo on Cuba, strengthening restrictions on tourism to Cuba, and ending economic practices that benefit the Cuban government and military.

The 2025 NSPM-5 also expands the criteria for the inclusion of entities or subentities on the Department of State’s Cuba Restricted List (CRL) in two ways. First, the 2025 memorandum directs the State Department to identify entities or subentities that act “for the benefit of” the Cuban military, intelligence, security services, or personnel (as opposed to just those entities or entities “under the control of, or act[ing] for or on behalf of” such services or personnel). Second, the 2025 memorandum directs the State Department to include on the CRL those entities or subentities with which direct or indirect financial transactions (as opposed to just “direct” financial transactions)

Although the 2025 memorandum restates regulatory initiatives from the 2017 memorandum, the 2025 memorandum states that it is “not intended to direct agencies to repeat actions already implemented” under the 2017 memorandum. Accordingly, in the short term, the 2025 memorandum is unlikely to result in significant regulatory changes or agency action aside from potential additions to the CRL under the expanded criteria. Still, the reissuance of NSPM-5 further reaffirms that the Trump administration intends to maintain a hardline approach to Cuba in President Trump’s second term.

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For more guidance on US economic sanctions and restrictions on Cuba, please contact a member of our Economic Sanctions team.