From Liechtenstein to Hong Kong: How Cuba uses shell companies to thumb its nose at embargo

A generic-sounding company headquartered in the tax haven of Liechtenstein has for the past 37 years served as the center of global shipping operations for the Cuban government, functioning under the radar while skirting a six-decade trade embargo.

When incorporated in 1984 in the principality of Liechtenstein, Acemex Management Company Limited was created as a means of survival. It grew into a business model, has been described as the work of a genius and has proved enduring.

Investigation reveals the network of hidden shell companies and secretive jurisdictions that allowed Fidel and Raúl Castro and now their military successors to borrow money and to buy, sell and charter the ships that bring in chemicals, fuel and construction supplies needed to build the growing tourism sector and export minerals.

The findings build on earlier reporting published in February as part of a global investigative collaboration called OpenLux, which spotlighted how the small European nation of Luxembourg was used as a camouflage for Cuban maritime operations.

The new investigation sheds light on little-known Acemex and the key players surrounding it — a pair of powerful Cuban brothers not named Fidel and Raúl, but Guillermo Faustino Rodriguez López-Calleja and his younger sibling Luis Alberto. The latter is a brigadier general blacklisted by the United States in 2020.

Acemex served as an umbrella covering dozens of other Cuba-linked companies whose ties to the island had to be disguised to operate effectively. Through Acemex, the brothers expanded the Cuban military’s control over economic activity and concentrated in few hands Cuba’s global shipping and logistics. In addition to providing European and Asian lenders and companies a degree of cover when engaged in Cuba, the shells also opened opportunities for rulers to enrich themselves.

“They have learned lessons, and you know practice makes perfect,” said Hal Eren, a veteran sanctions attorney who worked in the Treasury Department’s Office of Foreign Assets Control, or OFAC, from 1992 to 2000.

OFAC has the power to make a company a financial pariah, untouchable in global finance. Inexplicably it has not done so with Acemex.

Cuba’s reliance on the shell network has ebbed and flowed based on how much pressure it is getting from Washington, Eren said. The Obama administration eased up as it sought rapprochement. The Trump administration returned to a tougher line. The new Biden administration has not yet signaled its approach on Cuban sanctions.

“Every administration should use every tool available to hold accountable entities and individuals linked to despotic regimes in our region, as well as those enabling them to illegally enrich themselves through elaborate schemes and shell companies,” said Sen. Marco Rubio, R-Florida, a hardliner on Cuba. “It is time for our European allies to realize that the Cuban dictatorship and its cronies are getting richer on their shores at the expense of the hardworking people of Cuba who’ve endured decades of oppression.”

Soon after the Castro brothers seized power in 1959, at the height of the Cold War as the globe was falling into capitalist or communist camps, a complete U.S. trade embargo sought to choke the Cuban economy and bring about regime change.

The embargo was later expanded to try to shut Cuba out of the global banking system and more recently by extra-territorial financial sanctions designed to extract a price from anyone who does business with the Cuban government by making possible seizure of assets they might have in the United States. or blocking access to the U.S. financial system.

Since there is no Cuban private sector, went the theory, doing business there amounts to doing so with the government.

Cuba’s response was to create and expand a network of companies that is vast and more complicated than was previously known.

“The origin of it was sanctions busting,” said a former Western diplomat who was involved closely with the Castro brothers. “The history of this is long. It’s been going on a really long time.”

Cuba presently depends heavily on generic-sounding companies whose “owners” are hidden from public view in tiny Liechtenstein, all of just 62 square miles and about 39,000 people, bordering Switzerland and Austria.

“Liechtenstein, Luxembourg, these are favorite havens not only for the Cubans but for others who wish to stay under the radar,” said Eren, the former senior Treasury Department adviser on sanctions.

Acemex sits at the top of Cuba’s shipping pyramid. Misleadingly, the Cuban Chamber of Commerce as recently as 2019 listed Acemex as a “foreign company” from Liechtenstein that administers “maritime and financial businesses.” There’s no hint at the reality that it is actually Cuban. In the Liechtenstein corporate registry, Acemex lists Havana addresses for its directors.

Acemex “manages” several other shell companies — including some under U.S. sanctions — that buy and sell ships and move cargo, charter vessels and crews under other countries’ flags.

Here’s why it matters. Cheap labor provided by Cuban mariners allows the cash-strapped government to make a profit on operations, especially since Acemex bills in dollars but pays Cuban staff in pesos.

After February’s reporting on Luxembourg, numerous sources came forward to disclose the role of Acemex and how it helps the Cuban government conceal its activities. They contributed private documents and included four sources with first-hand knowledge of Acemex’s operations. All sought anonymity for fear of retaliation.

Acemex was originally designed to passively hold the assets of subsidiaries. But the Cuban government worried it was vulnerable to asset seizures. Acemex’s corporate structure changed, although it retained the kind of shareholder control commonly found in holding companies.

The earliest private description of Acemex was generic — that it was “involved in the sale of a variety of goods.” But the Liechtenstein corporate services firm Percuro Treuhandanstalt is listed as one of Acemex’s managers, and it is linked in the documents shared in the investigation to 100 shell companies, most liquidated but some still active.

The Acemex documents don’t list a chairman or owner. They do mention Guillermo Faustino Rodriguez López-Calleja, the focus of February’s OpenLux investigation, as chairman of Marsea Holdings and a managing member of Finsale Company Ltd., Gilmar Project Finance and NorthSouth Maritime Co. Ltd.

These four companies are described by the sources with first-hand knowledge as akin to Acemex’s operating subsidiaries.

On those companies, he’s joined by Andrés Ernesto Muñoz Campos, who also appears on corporate documents with Guillermo in Luxembourg, London and the Cyprus-registered Caroil Transport Marine Ltd. Caroil was blacklisted by the United States in 2019 for helping Venezuela bust U.S. sanctions on its state oil company.

The Liechtenstein documents also show as a director Marcos Arza Vizcaino, who was an earlier leader of Acemex through 2012, a point confirmed by Arza’s LinkedIn page. It shows him at Acemex from 1995 to 2012, later moving to the island’s state cruise ship business.

Tips and private Liechtenstein documents led to the Hong Kong corporate registry, where Acemex was also incorporated in September 2007.

Those Hong Kong documents list Liechtenstein as the main corporate domicile. Guillermo is listed as a director. So is Percuro Treuhandanstalt, the Liechtenstein firm that had the 100 shells under it.

A Western maritime industry source who has worked closely with the Cuban government said the Hong Kong incorporation corresponded with Cuba’s decision to shift its nickel mining exports to China.

Until that point, Cuban nickel went mostly to Canada and the Netherlands, where it had moved for decades because Dutch billionaire Willem van ‘t Wout enjoyed a decades-long friendship with Fidel Castro. Van ‘t Wout and his company did not respond to an online request for comment.

The move broadened Cuba’s relationship with China, a longtime ally. The shift also corresponded with a U.S. investigation into the Dutch bank ING, which had a 50% stake in a bank in Curacao called Netherlands Caribbean Bank, or NCB. The bank was incorporated as a joint venture in 1993, and Acemex was one of two Cuban partners in it.

In July 2006, OFAC designated the Curacao-based bank to the Specially Designated Nationals list, another one of the mechanisms of U.S. blacklisting, because of its substantial Cuban ownership. It did not blacklist Acemex.

The Caribbean bank was shut down, but ING ultimately acknowledged in 2012 that it moved more than $2 billion through the United States on behalf of Cuba and Iran — some of it through Netherlands Caribbean Bank. In a Treasury Department settlement ING agreed to forfeit $619 million.

Guillermo Rodríguez López-Calleja effectively runs two sanctioned companies — Anglo-Caribbean Shipping Company Limited and Caroil Transport Marine Ltd — yet neither Acemex nor he personally has been the target of sanctions. That’s all the more unusual since his powerful brother, Luis Alberto, has been.

Nordstrand Maritime & Trading, which has been on a Treasury blacklist since at least 1986, is also tied to Acemex. Nordstrand changed its name to NorthSouth Maritime, one of the four main operating companies now under Acemex in Liechtenstein. The Treasury Department’s sanctions list has apparently not yet caught up with that corporate change.

Asked about Guillermo and the outdated listing, the Treasury Department did not respond to repeated requests for comment, just as the Cuban government did not.

In response to written questions, the Embassy of Liechtenstein in Washington, after consulting various ministries, said the principality is under no duty to enforce U.S. financial sanctions.

“The Liechtenstein government and judiciary do not enforce OFAC sanctions, unless they correspond to sanctions adopted by the United Nations and are therefore binding on Liechtenstein or unless they correspond to sanctions adopted by the European Union, which are implemented by Liechtenstein,” said a statement from embassy. “Neither the UN nor the European Union have adopted sanctions against Cuba nor has Liechtenstein adopted unilateral sanctions against Cuba.”

However, Liechtenstein is concerned enough that its financial institutions could be blocked from the U.S. financial system for running afoul of Treasury blacklists that its Financial Markets Authority looks at non-compliance with OFAC sanctions.

“The prudential framework in Liechtenstein requires financial institutions to assess all the risks [territorial and exterritorial] associated with their business model,” said the statement.

But neither Acemex nor its leader have been sanctioned.

There are a multitude of reasons for not sanctioning a company or its leader, said Eren, the former OFAC adviser. These include considerations about possible reactions or intelligence gathering.

“It might serve U.S. government interest to not designate him, to let him roam free to follow him and see what he does,” the lawyer said.

But lack of resources at OFAC might play a part.

“They have a lot to do,” he added. “And they have very few people to do it.”

U.S. financial sanctions are designed so that any company doing business with a company sanctioned by the U.S. government could have its own assets seized in the United States. This extraterritorial approach is why Acemex is important. It helps the Cuban government get loans or maritime insurance in ways that are harder to track.

“One of the things Acemex did was convince banks to lend it money to buy ships. To do that, they had to tell the banks that they were not Cuban,” explained one of the sources. “You can’t do that with a company registered with an Old Havana address.”

The corresponding government ministry in Cuba generally has oversight for specific offshore entities, the source said, noting that in Acemex’s case “it was an open secret all these companies belong to the Ministry of Transport.”

In an unusual twist for communist Cuba, Acemex enterprises were designed to be profitable. The shells were not to be subsidized by the state, which regularly took a cut of the profits, said another source who was a longtime high-level official at one of these companies.

Still another source with direct knowledge of Acemex operations said that before Guillermo took over, Acemex’s revenue used for chartering vessels and covering expenses was kept in Greece, at the Banco Financiero Internacional (BFI) in Havana or at U.S.-sanctioned Cuban-owned Havana International Bank in London, currently named Havin Bank.

Financial statements for Acemex in 2006, obtained by McClatchy and the Herald, show a BFI bank account in Havana but make no mention of London and Greece. BFI now is controlled by a U.S.-sanctioned Cuban-company called Grupo de Administración Empresarial S.A.

Known as GAESA, the company is synonymous with the Cuban military, is run by Guillermo’s brother, Luis Alberto, and is why he was hit with U.S. sanctions in 2020.

The game of whack-a-mole has gone on for decades and has spanned the globe.

A leak of secret corporate documents from the law firm Mossack Fonseca — a dump that became known as the Panama Papers — showed how Cuba’s Ministry of Foreign Trade in the early 1990s, through the Compañía Panamericana S.A, created a string of disguised companies in Panama, the Bahamas and the British Virgin Islands. The shells were used to buy and sell medicine, cigars and food.

Declassified State Department documents also show the U.S. government sought to root out Swiss law firms that served as intermediaries for Cuba as far back as the 1970s.

New information now points to a man named Francisco Soberón as the architect of the enduring shell company network, atop which sits Acemex.

For decades Soberón represented several Cuban shipping, insurance and financial firms in Canada, the Netherlands and the United Kingdom, all of which is confirmed in his book, Gold, Dollar, and Empire. Soberón went on to become governor of the Central Bank of Cuba from 1995 to 2009.

“It was a scheme very well prepared by Soberón. Soberón was a genius,” insisted one of the sources who was part of the network and was present at government meetings when the business model was discussed.

Soberón convinced government officials to create a unified structure to bring them under singular control, a goal furthered by Guillermo.

A secret cable sent in May 2007 by the U.S. interests section in Cuba — the closest thing to a U.S. Embassy back then — identified Soberón as having led Acemex for 12 years, describing an “unexciting career in the shipping business” until tapped to lead the central bank. In reality, he was involved in the creation of Acemex in Liechtenstein, which gave a lifeline to the Cuban economy.

“Soberón was a protege of Raúl Castro’s, and his support for moderate economic reforms in the ‘90s placed him in the ‘reformist camp’ of GOC [government of Cuba] officials,” said the cable.

Raúl headed the Cuban Army for decades, and under his watch the military control over the economy expanded. It touches almost all facets of commerce via the military-industrial conglomerate GAESA headed by Luis Alberto. GAESA has become a focal point for Cuba’s Latin American relations too.

Over the past decade, GAESA absorbed several state companies and grew more powerful. Luis Alberto was even considered to be in the mix for becoming prime minister of Cuba.

And under his brother’s shadow, Guillermo, who was once a ship operator working for one of Acemex’s companies in Greece, shot up the corporate ladder to head Acemex.

“He was from the ‘royal family,’’‘ observed one of the former Cuban government officials. “He was not dumb but he didn’t deserve to be there.”

Asked about Guillermo, 63, another replied “un vive bien,” a Cuban phrase to describe the communist elite who enjoy the good life.

Guillermo’s rise also ushered in a change in Cuba. His name was splashed all over documents of Acemex companies. It represented a break from traditional use of secretaries and chauffeur as stand-ins on the offshore companies.

That, and his direct ownership of Mid-Atlantic, the Luxembourg company that controls Acemex-predecessor Anglo-Caribbean Shipping in London, has raised eyebrows among Cuba watchers.

‘What this suggests is that they are preparing for a change,” said one of the former Cuban officials, “as did the Soviet oligarchs who then took everything.”