725. May persons subject to U.S. jurisdiction providing carrier services to authorized travelers between the United States and Cuba provide such services via a third country?

Persons subject to U.S. jurisdiction are authorized to provide carrier services either directly or indirectly between the United States and Cuba for authorized travelers, provided that they hold any additional authorizations required by other U.S. government agencies. For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR § 515.572(a)(2).

The export or reexport of vessels or aircraft providing carrier services under 31 CFR § 515.572(a)(2) requires separate authorization from BIS. For a complete description of BIS’s regulatory requirements, see BIS’s Cuba webpage.