The USA Government has hit some Banks very hard ,should these Banks either deal directly with unfavoured regimes or even have customers who deal with unfavoured regimes.In this case a USA Bank could be hammered for assisting Boi.
It means USA can use their undoubted muscle and levy huge fines where they construe their rules are not being 100% adhered to.
Even if USA Bank could claim they are not party to any transaction, if even inadvertently they aided (in this case Cuba) they will be hammered.
If in Europe we have a USA Bank handling all SEPA transactions . So if that bank transfers to Cuba/Iran etc even from Bona fide EU Banks ,then it could be fined.
I do think BOI has join any embargo , it is just too risky a business.
I presume all other Banks will be adverse to sending funds to Cuba, if not they should be.
USA actions , after 50 years of embargo.
Unfair; yes.
Bullying; probably.
.
So is USA;
Unfair ; yes.
Bully boy; probably.