Washington’s expanded Cuba sanctions framework has created a new compliance reality for U.S. persons, foreign financial institutions, and global companies with direct or indirect exposure to Cuba.
In the premiere episode of Inside the Signal with Sigma360, Sigma360 Founder and CEO Stuart Jones Jr. speaks with Claire O’Neill McCleskey, co-founder of Clarity Compliance Consulting and former head of OFAC’s Compliance Division. Drawing on her experience at OFAC, FinCEN, HSBC, and as a financial attaché in Mexico, Claire explains how the expanded framework changes the risk calculus for organizations operating across jurisdictions.
Key takeaways:
- Understand how expanded designation authorities and secondary sanctions increase exposure for non-U.S. companies.
- Learn why the removal of the “knowingly” standard raises the stakes for foreign financial institutions.
- Explore why ownership, affiliates, state-linked networks, and adverse media context must be considered beyond sanctions-list screening.
- Identify practical steps organizations can take, including staff training, escalation procedures, network analysis, and defensible documentation.
Key timestamps:
- 00:00 Introduction and Guest Welcome
- 01:00 Claire O’Neill McCleskey’s Background
- 02:57 Why Clarity Compliance Consulting Was Founded
- 05:38 Shifting Sanctions Priorities and Enforcement Trends
- 08:15 Cartel and FTO Risk in Mexico
- 11:01 Cuba’s Expanded Sanctions Framework
- 15:06 Foreign Financial Institutions and Blocking Statutes
- 16:44 GAESA and Pressure on Cuba’s Economy
- 18:36 Cuba-Related Exposure, Red Flags, and Escalation
- 20:04 Practical Compliance Steps for Global Firms
- 22:43 Beyond List Screening: Networks and Investigations
- 26:03 Documentation and OFAC’s 10-Year Enforcement Horizon
- 28:03 Closing Thoughts
This discussion is provided for informational purposes only and does not constitute legal advice.
Music: “Minimalist (Neutral Focus)” by Sascha Ende (ende.app), licensed under CC BY 4.0.
