Trump Doubles Down on Failed Cuba Policy in National Security Presidential Memorandum

On June 30, 2025, the Trump administration announced its official Cuba policy by reissuing National Security Presidential Memorandum 5 (NSPM-5), mostly a reiteration of current policy and almost the same exact document issued in June 2017 that defined the first two years of his first administration.   

While specific regulations stemming from NSPM-5 will be announced later this July, and thus many of the policy details remain to be seen, it will likely result in further restrictions on and enforcement of legal travel to Cuba; the listing of additional Cuban military-linked entities with whom those subject to U.S. jurisdiction are prohibited from transacting; and new prohibitions on “indirect” transactions with these entities, which, despite ambiguities, could further chill trade with and investment on the island. 

Notably, NSPM-5 does not authorize secondary sanctions against foreign firms doing business with entities on the Cuba Restricted List, despite reports indicating otherwise. A new executive order invoking the International Emergency Economic Powers Act would be required to levy sanctions against foreign firms not subject to U.S. jurisdiction (Canadian, Spanish, Latin American, or otherwise) for doing business with Cuban military-linked firms.

Interestingly, NSPM-5 does not include some of the more extreme policy proposals being floated by certain members of Congress, and even goes so far as to call for increased engagement with Cuba in areas that advance U.S. interests. These include, but are not limited to, supporting Cuba’s independent private sector; engaging with Cuban authorities on law enforcement and aviation safety; boosting U.S. agricultural exports to Cuba; advancing scientific and environmental cooperation between the two countries; protecting plant, animal and public health; and enforcing final deportation orders against Cubans in the U.S., which would require the resumption of bilateral migration talks.

While ACERE applauds the call to enhance engagement in areas that advance U.S. objectives, overall, NSPM-5 represents a regressive and self-defeating approach to U.S.-Cuba relations that undermines U.S. national security, migration goals, economic interests, and regional stability.

Trump’s first-term Cuba policy, reflected in NSPM-5, only served to strengthen hardliners in Havana while punishing Cuba’s emerging private sector—the very actors who could drive economic and political reform on the island. Further restrictions on remittances and travel will continue to inflict unnecessary hardship on Cuban families, fueling migration crises that ultimately strain resources in the U.S. and countries in the region. Meanwhile, travel bans and visa restrictions for Cubans further complicate family reunification and discourage people-to-people exchanges that foster long-term democratic change. If strictly interpreted, NSPM-5 may also cede further geopolitical ground to U.S. adversaries like China and Russia, which have deepened their economic and military ties with Cuba and exploited the vacuum left by U.S. disengagement. By continuing to isolate Cuba, the U.S. will alienated key Latin American partners and reinforced anti-American sentiment in the region—weakening Washington’s ability to shape hemispheric policy on issues like migration, drug trafficking, and regional security.

A policy of pragmatic engagement offers a more effective path forward. By reopening diplomatic channels, easing travel and trade restrictions, and supporting Cuba’s private sector, the U.S. can reduce push factors that have resulted in the historically largest wave of migration from Cuba; counter Chinese and Russian inroads on the island; empower Cuba’s civil society by facilitating remittances and entrepreneurship; advance U.S. economic interests by allowing American businesses to compete in Cuban markets; and strengthen regional influence by rebuilding trust with Latin American partners. 

While NSPM-5 largely echoes the restrictions from President Trump’s first term — most of which have been in place since 2017, with the exception of the last few days of Biden’s term in office — its impact will hinge on how much leeway federal agencies are given to shape and enforce the coming regulations.

ACERE urges the Trump administration to reconsider NSPM-5 and instead craft a Cuba policy roadmap based on calibrated engagement that prioritizes diplomacy, economic leverage, and strategic patience. The U.S. does not need to endorse the Cuban government to recognize that hostility and isolation have failed for over six decades, while pragmatic engagement offers a realistic path toward the incremental reforms the U.S. wants to see on the island.