The NGO sent an analysis on the issue to Alena Douhan, United Nations special rapporteur on the negative repercussions of unilateral coercive measures.
MIAMI, United States. – The Cubalex Legal Information Center sent Alena Douhan, United Nations special rapporteur on the negative repercussions of unilateral coercive measures, an analysis in which she maintains that the main obstacles to the exercise of economic and social rights in Cuba come from internal decisions of the State, despite the restrictive effects of the US embargo.
The analysis was sent on November 7, about four days before Douhan began his official visit to the Island, according to a note published on the NGO’s website.
The organization explained that the embargo does not constitute “a monolithic regime of absolute prohibitions,” but rather a system with specific exceptions and margins for commercial and humanitarian interaction. Furthermore, he stressed that, although the sanctions reinforce Havana’s financial isolation and limit its access to international payment systems, there are humanitarian exceptions, as well as constant trade flows between the United States and Cuba in the last 10 years. He also pointed out the authorization of remittances, donations, technological exports and operations linked to the private sector under the “Support for the Cuban People” license, created by the Treasury Department during the 2014–2016 thaw.
Cubalex recalled that US regulations allow the export of information technologies and equipment to improve connectivity without this implying direct investments in state infrastructure. However, the NGO highlighted, the Cuban Government has chosen to maintain strict control over telecommunications, considered a national security sector, which has led to a preference for Chinese suppliers such as Huawei and ZTE. He also highlighted that Havana rejected projects from US companies, including one from Google aimed at expanding internet access on the island, despite the fact that these initiatives were contemplated in Washington’s regulatory flexibilities.
The narrative of the “blocked country”
Cubalex warned that the Cuban Government usually instrumentalizes the restrictions of the embargo to support the discourse of a “generalized blockade”, attributing to it a scope greater than the real one. This narrative is deployed even in sectors where there are import alternatives, such as generic medicines and manufactures from countries with which Cuba maintains active relations.
The analysis also recalls that the embargo functions, in practice, not only as a sanctions regime, but as a symbolic resource of internal political discourse. Cuban authorities systematically attribute the shortage of essential goods to United States sanctions, even though the country’s own economic structure and the absence of reforms prevent it from taking advantage of open trade routes or international donations.
In this sense, Cubalex maintains that economic stagnation derives, above all, from state centralization, the lack of transparency and an internal regulatory framework that limits private autonomy, prevents transforming cooperation into sustainable investment and consolidates the country’s structural dependence.
The “internal blockade”: restrictions that do not depend on Washington
According to Cubalex, even if the United States lifted the embargo tomorrow, Cuba’s internal crisis would not be resolved automatically, because the structural causes of social and economic precariousness originate in the State’s own policies. The organization highlighted that the most significant restrictions—revocable licenses, state banking controls, hiring caps, and political authorizations to operate—are not dictated by the embargo, but by the internal control model.
The NGO considers that, although external relief could reduce financial costs or improve access to credit and technology, there are no guarantees that these benefits will translate into social improvements, because this depends on the orientation of public policies that today do not point to deep reforms.
The organization also recommended Alena Douhan apply an investigation method based on direct observation and documentary review, including consultation of licenses, decrees and resolutions; and he stressed that in Cuba there are risks of retaliation and self-censorship, which is why he advised asking closed and verifiable questions, as well as requesting access to administrative files and public records to verify the real application of norms linked to humanitarian exceptions and cooperation mechanisms.
Douhan, UN special rapporteur on unilateral coercive measures, Alena Douhan, made an official visit to Cuba from November 11 to 21 to evaluate the impact of sanctions on human rights. The Office of the High Commissioner (OHCHR) advertisement that the expert will present “her conclusions and recommendations in a report that she will submit to the 63rd session of the Human Rights Council in September 2026.”
