The Cuban side of the question
On the Cuban side, a US citizen is a foreign national like any other. That means they generally cannot buy on the open home-sale market reserved for Cuban citizens and permanent residents. The realistic routes, residency, marriage, inheritance, or approved developments, apply the same way they do to other foreigners.
So even before US rules enter the picture, an American faces the same structural limits as any non-resident. This is information only and is not legal advice; the interaction of two legal systems makes professional counsel especially important here.
The US legal reality: OFAC
The decisive layer for many Americans is US law. The Office of Foreign Assets Control administers the Cuban Assets Control Regulations at 31 CFR Part 515, which restrict a wide range of financial transactions between US persons and Cuba. Property purchases involve exactly the kind of financial dealings these rules govern.
Because of this, a US person cannot assume that a transaction permitted under Cuban law is also permitted under US law. The two can point in different directions, and the US restrictions apply to US persons regardless of where they are physically located. Anyone in this position needs qualified US legal advice before acting.
Helms-Burton and claim exposure
There is a further US dimension. Under Title III of the Helms-Burton Act, there is potential legal exposure connected to property in Cuba that was confiscated from US nationals after 1959. Some Cuban real estate has a contested history, and buyers can find themselves entangled in claims they never anticipated.
This is a factual reality, not a political statement. It simply means that for a US person, the history of a specific property and the reach of US sanctions law are as important as anything in the Cuban registry.
Brought together, the two legal systems can point in opposite directions at the same time. Cuban law might, through some route, appear to permit a foreigner to hold property, while US law simultaneously restricts the financial steps needed to get there and attaches potential claim exposure to the asset itself. For a US citizen, the safest reading is that neither system's permission means much without the other's, and that competent advice on both sides is not optional. This page states the framework only; it is not a substitute for that advice.