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1057. Are remittance forwarding service providers required to independently verify that a sender’s family or donative remittance is authorized when processing such remittances?


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. 

Date Released
June 8, 2022