President Donald Trump on Friday signed an executive order authorizing penalties against foreign banks and other companies anywhere in the world that do business with the Cuban government. 

The order, issued under the International Emergency Economic Powers Act and other authorities, builds on a January 29 declaration by the president that Cuba poses an “unusual and extraordinary threat” to U.S. national security and foreign policy. It directs the Treasury and State departments to block the U.S. assets of “any foreign person” determined to operate in Cuba’s energy, defense, metals and mining, financial services, or security sectors, and gives those agencies authority to add other sectors of the Cuban economy at their discretion.

Under the order, the Treasury secretary, in consultation with the secretary of state, may impose two penalties on any foreign financial institution found to have conducted or facilitated “any significant transaction” for sanctioned persons: prohibiting or imposing strict conditions on U.S. correspondent or payable-through accounts, and freezing the institution’s U.S. assets. 

The order’s reach extends well beyond the financial sector. It authorizes asset freezes on foreign persons determined to have “materially assisted, sponsored, or provided financial, material, or technological support” to the Cuban government or to anyone sanctioned under the order. It also targets current and former Cuban government officials, entities owned or controlled by the government, those who act “directly or indirectly” on its behalf, and persons judged responsible for “serious human rights abuse in Cuba” or for corruption “related to the Government of Cuba.”

“This is a clear escalation,” Brian Fonseca, director of the Jack D. Gordon Institute for Public Policy at Florida International University, told the Miami Herald. “Secondary sanctions are the centerpiece here. They’re designed to reach beyond Cuba and force global banks and companies to stop enabling the regime’s economic survival.”

John Kavulich, president of the U.S.-Cuba Trade and Economic Council, told the newspaper that the order had the potential to be “almost immeasurably impactful upon Cuba,” particularly in banking, but cautioned that the practical effect would depend on enforcement, given what he described as the administration’s previously thin implementation of earlier Cuba-related orders.

Still, the threat alone could discourage foreign banks and companies from engaging with the island, the Herald noted. 

The order contains an unusually broad family-member provision, authorizing the blocking of property of any “adult family member” of a designated person. It also suspends U.S. entry for foreign nationals meeting the sanctions criteria, treating them like persons subject to United Nations Security Council travel bans.