Nearly 4,000 Miami-Dade Businesses Just Received Cuba Compliance Notices.

Did You Get One? Here’s Why You May Need a Criminal Defense Attorney — Not Just a Business Lawyer.
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By Dennis Gonzalez Jr., Esq. — Former Miami-Dade Prosecutor | Criminal Defense Attorney
Published March 1, 2026 | (305) 209-0384 | dgonz.com

Nearly 4,000 Miami-Dade Businesses Just Received Cuba Compliance Notices.

Did You Get One? Here’s Why You May Need a Criminal Defense Attorney — Not Just a Business Lawyer.

By Dennis Gonzalez Jr., Esq. — Former Miami-Dade Prosecutor | Criminal Defense Attorney

Published March 1, 2026 | (305) 209-0384 | dgonz.com

If you own a business in Miami-Dade County and it has any connection to Cuba — travel services, cargo shipping, remittances, import/export, telecommunications, or any other commercial activity involving the island — you may have received a compliance notice from the Miami-Dade County Tax Collector’s Office in recent weeks.

You are not alone. According to the Tax Collector’s Office, 3,909 compliance notices have been sent to Miami-Dade businesses suspected of engaging in Cuba-related commercial activity. The notices demand that you confirm whether your business conducts such activity and, if so, provide documentation of federal legal authorization — including any licenses or certifications from the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) or the U.S. Department of Commerce.

Many business owners are treating this like routine paperwork. That is a serious mistake. How you respond to this notice — or fail to respond — can determine whether you face a simple administrative issue or a federal criminal investigation.

As a former Miami-Dade prosecutor and criminal defense attorney who serves the Cuban-American community, I want to walk you through exactly what is happening, why it matters, and what you should do right now.

What Are These Compliance Notices?

The Miami-Dade County Tax Collector, Dariel Fernandez, has been conducting a systematic review of businesses with potential ties to Cuba-related commercial operations. This effort did not start overnight. The Tax Collector’s Office began sending initial waves of letters as early as October 2025, and by December 2025, businesses that failed to respond had their Local Business Tax Receipts revoked — effectively shutting them down.

The current wave of 3,909 notices represents a dramatic expansion of this enforcement effort. The legal basis comes from two sources:

• Section 205.0532, Florida Statutes — This state law provides that any local governing authority may revoke or refuse to renew a business tax receipt if the business, or its parent company, is doing business with Cuba in violation of federal law.
• Miami-Dade County Code, Administrative Order No. 3-13 — Issued under the authority of Section 4.02 of the Metropolitan Dade County Charter and Ordinance 93-45, this order mandates that the Tax Collector revoke or refuse to renew Local Business Tax Receipts for any business engaged in commerce with Cuba in violation of federal law, specifically upon written confirmation from OFAC that the entity lacks a valid federal license.

Adding further urgency, President Trump signed an Executive Order on January 29, 2026, titled “Addressing Threats to the United States by the Government of Cuba,” which declared a national emergency under the International Emergency Economic Powers Act (IEEPA) and directed federal agencies to intensify enforcement of Cuba-related restrictions. The Tax Collector’s Compliance Transparency Page has explicitly cited this Executive Order as additional context for its expanded review.

What Happens If You Don’t Respond — Or Respond Wrong?

There are two levels of consequences, and most business owners only understand the first one.

Level 1: Administrative Consequences (Loss of Your Business License)

If you fail to respond to the compliance notice, or if you cannot demonstrate valid federal authorization for your Cuba-related business activity, the Tax Collector will revoke your Local Business Tax Receipt. This is not a theoretical threat. In December 2025, the Tax Collector’s Office revoked the Local Business Tax Receipts of multiple businesses, including travel agencies and multi-service companies, that failed to respond to earlier notices. Without a valid Local Business Tax Receipt, your business cannot legally operate in Miami-Dade County. Period.

Level 2: Federal Criminal Exposure (This Is Where It Gets Dangerous)

Here is what most business owners and even many attorneys do not fully appreciate: the Tax Collector’s Office has stated it is coordinating with federal agencies responsible for sanctions enforcement and export controls. This means your response to a county compliance notice could end up on the desk of a federal prosecutor.

Cuba-related commercial transactions in the United States are governed by the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, administered by OFAC under the authority of the Trading With the Enemy Act (TWEA), 50 U.S.C. §§ 4301–4341. These are not suggestions. They are among the most strictly enforced sanctions regulations in the world.

The criminal penalties for willful violations are severe:

• 50 U.S.C. § 4315(a) (TWEA Criminal Penalties): Any person who willfully violates any provision of the Trading With the Enemy Act, or any license, rule, or regulation issued under it, faces criminal fines of up to $1,000,000 and, for a natural person, imprisonment of up to 20 years, or both.
• 50 U.S.C. § 4315(b)(1) (Civil Penalties): The Secretary of the Treasury may impose civil penalties of up to $111,308 per violation (as adjusted for inflation under 31 CFR § 501.701(d)).
• 50 U.S.C. § 4315(b)(2) (Asset Forfeiture): Any property, funds, securities, papers, or other articles involved in a violation may be forfeited to the United States government.
• 18 U.S.C. § 1001 (False Statements): If you provide false information in response to a government inquiry — whether to the Tax Collector’s Office, OFAC, or any federal agency — you face an additional charge of up to 5 years’ imprisonment. This applies even if the underlying Cuba-related activity turns out to have been authorized.

Read that again: even if you believe your business activity is legal, providing inaccurate or incomplete information in your response could independently create criminal liability.

How an Administrative Notice Becomes a Criminal Case

Here is a scenario I see playing out for Miami-Dade business owners right now:

1. You receive the compliance notice. You think it is just local government paperwork. You respond on your own, without legal counsel.
2. Your response contains inaccuracies. Maybe you overstate your OFAC authorization. Maybe you claim a general license applies when it does not. Maybe you omit certain transactions. You did not intend to lie — you just did not understand the complex regulatory framework.
3. The Tax Collector’s Office shares your response with federal agencies. The office has already stated publicly that it is coordinating with federal agencies responsible for sanctions enforcement. Your inaccurate response is now in the hands of OFAC or the Department of Justice.
4. A federal investigation opens. OFAC begins a civil investigation. If willfulness is suspected, the case may be referred for criminal prosecution. Under OFAC’s enforcement guidelines (31 CFR Part 501, Appendix A), investigations can lead to cautionary letters, warning letters, cease-and-desist orders, civil penalties, license revocation, or criminal referral.
5. You now face federal criminal charges. What started as a county compliance notice has become a federal case with the possibility of up to 20 years in prison and $1,000,000 in fines. Your business is shut down. Your assets may be seized.

This is not hypothetical. This is the enforcement pipeline that federal and local authorities have built. And with 3,909 businesses now under review and a sitting President who has declared a national emergency specifically targeting Cuba, the enforcement environment has never been more aggressive.

⚠ Did You Receive a Compliance Notice?

Do not respond to the Tax Collector’s Office without speaking to an attorney first. Request a confidential consultation — I will review your notice and advise you on your options before any deadline passes.

REQUEST ATTORNEY CALLBACK

Or call directly: (305) 209-0384  |  Hablo español

Common Mistakes Business Owners Make

In my experience as a former prosecutor and now as a criminal defense attorney, these are the most dangerous mistakes I see:

1. Ignoring the notice entirely. Silence is treated as an admission that you lack federal authorization. Your Local Business Tax Receipt will be revoked. Worse, the lack of response may signal to federal investigators that you have something to hide.
2. Responding without an attorney. The OFAC regulatory framework governing Cuba sanctions is extraordinarily complex. The CACR spans dozens of sections covering general licenses, specific licenses, prohibited transactions, authorized transactions, and exceptions. A business owner who tries to navigate this alone is likely to make statements that are legally inaccurate — and potentially incriminating.
3. Assuming a general license covers your activity. OFAC issues both general licenses (which authorize certain categories of transactions without individual application) and specific licenses (which require direct application and approval). Many business owners assume they operate under a general license without verifying that every element of their activity falls within the license’s scope. Under the Trump administration’s tightened Cuba policies, several general licenses have been narrowed or revoked.
4. Overstating compliance. Telling the county “we have OFAC authorization” when your authorization has expired, does not cover your specific activities, or never existed is a federal offense under 18 U.S.C. § 1001. This statute punishes false statements made in any matter within the jurisdiction of the federal government.
5. Thinking this is only a local issue. The Tax Collector’s review is local. But the federal sanctions framework it implicates is not. Cuba sanctions enforcement is handled by OFAC, the Department of Justice, the FBI, Homeland Security Investigations (HSI), and the Bureau of Industry and Security (BIS). When the Tax Collector’s Office says it is “coordinating with federal agencies,” take that at face value.

Why You Need a Criminal Defense Attorney — Not Just a Business Lawyer

Most business attorneys can help you file paperwork and respond to an administrative inquiry. But this situation requires someone who understands how administrative responses become evidence in criminal prosecutions — because that is exactly the risk you face.

As a former Miami-Dade prosecutor, I know exactly how the government builds cases. I know what investigators look for in your responses, what language triggers further scrutiny, and how seemingly innocent statements can be used against you. I also understand the Cuban-American community because I am part of it.

Here is how I can help:

• Evaluate your compliance position. I will review your business operations, identify exactly which OFAC regulations and licenses apply to your activity, and determine whether you have valid federal authorization.
• Craft a legally protected response. Your response to the compliance notice must be accurate, complete, and strategically drafted to protect you from both administrative action and potential criminal liability. I draft responses that satisfy the county’s inquiry without creating unnecessary exposure.
• Protect your Fifth Amendment rights. If there is any possibility that your business activity was not properly authorized, you have constitutional rights that must be preserved. A business lawyer may not think about criminal exposure. A criminal defense attorney will.
• Interface with federal authorities if necessary. If your case has already attracted federal attention, you need an attorney who is comfortable dealing with OFAC, the DOJ, and federal investigators. This is criminal defense territory.
• Communicate with you in your language. I am fluent in Spanish and serve the Miami-Dade Cuban-American community. You will not need a translator. You will not need to worry about cultural misunderstandings. You will speak directly with your attorney in the language you are most comfortable with.

What You Should Do Right Now

If you have received a compliance notice from the Miami-Dade County Tax Collector’s Office regarding Cuba-related business activity, take the following steps immediately:

1. Do not ignore the notice. There is a deadline to respond, and failure to respond carries immediate consequences.
2. Do not respond on your own. Anything you say in writing can and will be shared with federal authorities.
3. Gather your documentation. Locate any OFAC licenses (general or specific), BIS certifications, or other federal authorizations related to your Cuba-related business activity.
4. Call a criminal defense attorney who understands both the federal sanctions framework and the local enforcement landscape. This is exactly what I do.

DENNIS GONZALEZ JR., ESQ.

(305) 209-0384

Former Miami-Dade Prosecutor | Criminal Defense Attorney

Hablo español. Consulta disponible las 24 horas.

dgonz.com | 786.Law | @abogado.305

Disclaimer: This blog post is for informational purposes only and does not constitute legal advice. Reading this article does not create an attorney-client relationship. If you have received a compliance notice, call Dennis Gonzalez Jr., P.A. (305) 209-0384