754. Is the U.S. originating bank, U.S. intermediary bank, or U.S. beneficiary bank required to independently verify that a person subject to U.S. jurisdiction is not engaging in a direct or indirect financial transaction as defined in § 515.209 when processing Cuba-related transactions?

No. To the extent the transaction involves an entity or subentity on the Cuba Restricted List, a financial institution can rely on the statements of its customer or information available to them in the ordinary course of business that the transaction is authorized unless it knows or has reason to know the 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 a transaction involving Cuba or a Cuban national and which may be authorized pursuant to the Cuban Assets Control Regulations.

Date Updated: September 29, 2026