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792. Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with Cuban nationals located outside of Cuba?


U.S.-owned or -controlled entities in third countries may provide goods and services to a Cuban national located outside of Cuba, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to or from Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.585.

Other general licenses may authorize persons subject to U.S. jurisdiction, including U.S.-owned or-controlled entities in third countries, to engage in certain specified transactions with Cuban nationals that involve the commercial exportation of services to Cuba. For example, 31 CFR § 515.572(a)(5) authorizes persons subject to U.S. jurisdiction to provide certain civil aviation safety-related services to Cuba or to Cuban nationals, wherever located. 

Date Released
November 8, 2017