Mexico is gearing up to resume oil shipments to Cuba through privately owned companies rather than state entities, President Claudia Sheinbaum announced on June 22, floating a manoeuvre that would sidestep Washington's blockade while leveraging Havana's newly enacted economic liberalisation measures. The initiative, though, faces a materially harder sanctions environment than when Mexico first suspended its deliveries in January.

The backdrop is a near-total collapse in Cuban energy supply. Cuba produces only around 40% of the petroleum it requires domestically and has historically depended on imports from Venezuela, Russia and Mexico. That structure disintegrated on January 3 when a US military operation resulted in the capture of Venezuelan president Nicolás Maduro, halting Caracas' subsidised deliveries. Mexico stepped into the breach but suspended its own Pemex-operated shipments after the Trump administration issued an executive order on January 29 declaring a national emergency over Cuba and threatening tariff penalties on any country supplying hydrocarbons to the island. Only one oil shipment has reached Cuba since: a Russian tanker docking on March 30 carrying 730,000 barrels of crude. A second Russian vessel turned around off the coast of Brazil on May 27 without arriving. Cuba's Ministry of Energy and Mines warned on May 14 that the country had run out of oil and diesel entirely.

The humanitarian toll is severe and worsening. The record power deficit was registered on May 13 and 14, reaching between 2,153 and 2,174 MW and leaving 70% of the country without power. Grocery store shelves are empty, hospitals can barely function, and the lack of diesel has stalled the agricultural sector, marine vessels and trucks. Cuba's economy is forecast to contract by between 6% and 15% this year, according to estimates cited by multiple analysts.

Sheinbaum's proposed workaround pivots on the 176 economic reforms approved unanimously by Cuba's National Assembly on June 18 under Prime Minister Manuel Marrero. Among them, documented under the "Energy Transformations" section, is a provision allowing private domestic companies, cooperatives, joint ventures and foreign investors to participate in fuel importation and distribution — a sector historically monopolised by the state entity Unión Cuba-Petróleo (CUPET).

Sheinbaum argued this reform creates legal space for Mexican private operators to engage commercially with the island without routing supply through state channels. "The mechanism would be through private companies that have permits to transport fuel to Cuba," she said at her daily press conference, without naming firms or specifying a timeline. Her foreign ministry has indicated it can facilitate introductions for interested businesses.

The sanctions deterrent, however, has grown considerably more severe since January. The Trump administration's original tariff threat was subsequently invalidated: on February 20, the US Supreme Court ruled that IEEPA does not give the president authority to impose tariffs. Washington's response was to escalate through a different instrument. On May 1, President Trump signed Executive Order 14404 establishing a new Cuba sanctions authority under IEEPA, authorising OFAC to impose blocking sanctions on foreign persons determined to operate in Cuba's energy sector — covering oil and gas supply, electricity generation, distribution and fuel trading — as well as defence, metals and mining, and financial services.

Critically, the order extends secondary sanctions risk to foreign financial institutions that process transactions on behalf of designated Cuban entities. Any Mexican private company with US dollar banking exposure or American investors faces the prospect of SDN designation and loss of access to the US financial system.

OFAC has released no guidance on what constitutes "operating in" Cuba's energy sector for the purposes of secondary sanctions exposure, and there is no price-cap carve-out comparable to the Russia framework. That ambiguity will almost certainly be read conservatively by compliance officers at any firm with material US exposure.

Whether Mexican companies will accept the commercial risk remains the article's open question. Unlike the state-backed Pemex, which has the sovereign weight of the Mexican government to cushion geopolitical friction, private mid-sized transporters and fuel traders possess no such safety net; losing access to US dollar clearing accounts represents an overnight death sentence.

Sheinbaum is offering political cover and ministry-facilitated introductions, but no indemnification against US enforcement action. Cuban authorities themselves cautioned that implementation of the reforms could be slow, and acknowledged that the measures will not be viable if the US maintains its current posture. The designation of GAESA, the Cuban sprawling military's commercial conglomerate, as an SDN under the May order further narrows the universe of Cuban counterparties any Mexican firm could legally transact with, particularly now that OFAC's wind-down period for existing GAESA relationships expired on June 5.

Mexico's prior oil relationship with Cuba was commercially structured and paid. Pemex's then-director Víctor Rodríguez Padilla stated in February that Cuba had paid $496m for crude and refined products during 2025 with no overdue invoices. But the sanctions environment that private firms would now navigate bears little resemblance to what Pemex faced before January.