No. Under 31 CFR § 515.572(a)(3), banking institutions, as defined in § 515.314, including U.S.-registered brokers or dealers in securities and U.S.-registered money transmitters, are authorized to provide services in connection with the collection, forwarding, or receipt of remittances authorized pursuant to the CACR, subject to certain conditions. In addition, under § 515.570(h), banking institutions are authorized to unblock and return blocked remittances that would have been authorized under § 515.570(a) or (b). Banking institutions may rely on the statements of their customers that remittance transactions are authorized unless they know or have reason to know a transaction is not authorized. A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures with respect to a transaction involving Cuba or a Cuban national.
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