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. 

Effective June 9, 2022, in consultation with the Department of State, OFAC amended the CACR to implement elements of policy changes announced by the Administration on May 16, 2022 to increase support for the Cuban people.

Professional meetings and conferences in Cuba:  Effective June 9, 2022, OFAC amended 31 CFR § 515.564(a) to include a general license authorizing, subject to conditions, travel-related and other transactions incident to attending or organizing professional meetings or conferences in Cuba, such as   professional meetings or conferences to support expanded internet access and remittance processing and to provide additional support and training to independent Cuban entrepreneurs.  OFAC also amended and added cross-references to § 515.564(a) in notes to §§ 515.534, 515.542, 515.547, 515.572, 515.577, and 515.591.

Group people-to-people and other academic educational activities:  Effective June 9, 2022, OFAC amended § 515.565(a) to remove certain restrictions on authorized academic educational activities. OFAC also amended § 515.565(b) to authorize group people-to-people educational travel conducted under the auspices of an organization that is subject to U.S. jurisdiction and that sponsors such exchanges to promote people-to-people contact, provided such travelers are accompanied by an employee, paid consultant, or agent of the sponsoring organization.  Travel-related transactions authorized pursuant to § 515.565(b) must be for the purpose of engaging, while in Cuba, in a full-time schedule of activities that are intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities; and will result in meaningful interactions with individuals in Cuba.  This amendment does not authorize individual people-to-people travel.  Travel for tourist activities is not permitted.

Remittances:  Effective June 9, 2022, OFAC amended § 515.570(a) to remove the $1,000 quarterly limit on family remittances to Cuban nationals who are close relatives.  OFAC also added § 515.570(b) to authorize donative remittances to Cuban nationals who are not prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or close relatives of a prohibited official of the Government of Cuba or prohibited member of the Cuban Communist Party.  Finally, OFAC added a general license in § 515.570(h) authorizing the unblocking and return of previously blocked remittances, provided they would be authorized under the revised § 515.570(a) or (b).