Raises the cost of third-country trade with the US for Cuba-linked energy shipments: The order creates a direct trade penalty channel that can be applied to a supplier country’s exports to the US based on its oil dealings with Cuba.

Expands US economic pressure beyond bilateral Cuba measures: By tying tariffs to third-party conduct, the policy broadens leverage from US–Cuba restrictions to countries and firms involved in Cuba’s energy supply chain.

Increases compliance and contracting risk for shippers, traders, and refiners: The “directly or indirectly” standard widens exposure for intermediaries and could force counterparties to reassess documentation, routing, and contractual representations tied to Cuba-related cargoes.