1272. How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect those previously authorized "U-turn" transactions in which Cuba or a Cuban national has an interest?

Effective September 30, 2026, OFAC amended 31 CFR § 515.584(d) by removing the authorization for banking institutions subject to U.S. jurisdiction to process transactions that originate and terminate outside the United States, provided that neither the originator nor the beneficiary was a person subject to U.S. jurisdiction (the "U-turn general license"). Pursuant to 31 CFR § 515.584(d), banking institutions subject to U.S. jurisdiction are now only authorized to reject (vice block) such transactions.

To account for the removal of the "U-Turn" authorization, OFAC also amended § 515.584(e) to remove the authorization for the unblocking and return of any transfer that would have been authorized pursuant to the prior "U-Turn" general license.