Hapag-Lloyd and CMA CGM Suspend All Cuba Bookings Under US Executive Order, Creating Sanctions Compliance Flashpoint for European Shipping Groups
Two of the world's largest container shipping companies — Germany's Hapag-Lloyd and France's CMA CGM — have suspended all bookings to and from Cuba until further notice, each citing a US executive order issued on 1 May 2026 that broadened existing US sanctions on commerce with Cuba. The executive order extended US sanctions to cover "any foreign person" operating in Cuba's energy, defence, metals and mining, financial services, or security sectors, or any other sector designated by the President. The breadth of the order created what Hapag-Lloyd described as "compliance risks" that made continued Cuba bookings untenable. The suspensions could affect up to 60% of Cuba's shipping traffic by volume, according to sources with direct knowledge — a severe blow to an island already facing acute supply shortages. The key legal concern for both carriers is exposure to liability linked to Gaesa, a Cuban military-linked business conglomerate that is heavily sanctioned by the United States and has pervasive involvement in Cuba's commercial import/export infrastructure. Continuing to ship goods transiting Gaesa-linked entities would expose both carriers to secondary sanctions risk in the US market. The options reportedly under consideration include a permanent halt to Cuba shipping or a structured arrangement with the Trump administration permitting shipments solely to Cuba's private sector. The situation also forced Sherritt International, a Canadian miner, to exit its Cuban nickel and cobalt operations after decades of investment.
Why this matters
This is a live secondary sanctions compliance scenario with direct relevance to European companies and their London-based legal advisers. Hapag-Lloyd and CMA CGM are both non-US companies subject to US secondary sanctions — a growing legal phenomenon where US executive action extends compliance obligations to foreign persons dealing with sanctioned jurisdictions. The breadth of the 1 May executive order — covering "any other sector" at Presidential discretion — creates significant legal uncertainty for European businesses with Cuban exposure, as the scope of prohibited activity is effectively open-ended. Disputes and sanctions lawyers at London firms will be advising clients on whether existing Cuba-related contracts can be performed lawfully, what force majeure or sanctions carve-out clauses apply, and how to structure any wind-down of Cuban operations without triggering further liability.
On the Ground
A trainee on a sanctions compliance matter arising from these suspensions would assist with sanctions screening memos, checking whether counterparties have any Gaesa connections against OFAC (the US Office of Foreign Assets Control) and UK OFSI (Office of Financial Sanctions Implementation) designations lists. They would also prepare choice-of-law summaries for existing contracts with Cuban counterparties and assist with the drafting of force majeure notices where performance has become unlawful.
Interview prep
Soundbite
European carriers suspending Cuba operations shows US secondary sanctions can override contractual obligations for non-US companies operating through London.
Question you might get
“How would you advise a UK-based company with a long-term supply contract with a Cuban entity that has now become unperformable following the US executive order — what clauses would you look to, and what are the risks of getting it wrong?”
Full answer
Hapag-Lloyd and CMA CGM have suspended Cuba shipping after a US executive order broadened sanctions to cover foreign persons operating across virtually any sector of the Cuban economy. The legal crux is secondary sanctions exposure: even though both carriers are non-US companies, their US market access means they cannot risk dealing with Gaesa-linked entities. For disputes and regulatory lawyers in London, this creates immediate work: advising clients on whether existing shipping contracts can be performed, assessing force majeure and sanctions carve-out clauses, and structuring any operational wind-down. The open-ended drafting of the executive order — covering 'any other sector' — is particularly significant because it creates ongoing legal uncertainty rather than a fixed compliance perimeter, which is the type of ambiguity that generates sustained advisory and litigation mandates.
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