Effective September 30, 2026, OFAC amended § 515.564 to eliminate the authorization related to the attendance at, or organization of, professional meetings or conferences in Cuba. Persons subject to U.S. jurisdiction are no longer authorized to attend or organize professional meetings or conferences in Cuba. OFAC is replacing that authorization with a limited wind down authorization for persons subject to U.S. jurisdiction who were in Cuba on September 30, 2026 pursuant to the former professional meetings authorization to engage in travel-related and other previously authorized transactions through October 30, 2026, provided they depart Cuba by October 30, 2026. In addition, OFAC is also authorizing persons to terminate and obtain refunds for travel and related transactions for trips consistent with the former professional meetings authorization until October 30, 2026.

Effective September 30, 2026, OFAC narrowed the authorization for persons subject to U.S. jurisdiction, including U.S. academic institutions and their faculty, staff, and students, to engage in certain education-related transactions involving Cuba. Persons subject to U.S. jurisdiction that wish to engage in educational activities, including travel-related transactions, involving Cuba must now fit within one of these categories:

• Educational Activities by Accredited U.S. Undergraduate or Graduate-Degree Granting Institutions: 31 CFR § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate-degree granting institutions, their students, and full time permanent employees to engage in certain educational activities, such as noncommercial research in Cuba specifically related to Cuba and for the purpose of obtaining a graduate degree, under the auspices of the academic institution without accompaniment by a representative from a sponsoring organization.
• Educational Activities by Other Institutions: § 515.565(a)(2) authorizes certain educational activities not authorized under § 515.565(a)(1), such as certain educational exchanges sponsored by Cuban or U.S. secondary schools, provided that the activity takes places under the auspices of an organization subject to U.S. jurisdiction and that all travelers are accompanied by a representative of the sponsoring organization.

Additionally, OFAC removed the previous authorization at § 515.565(b) for group people-to-people educational travel. 
OFAC replaced these education-related authorizations with "grandfathering" provisions authorizing certain educational travel and group people-to-people educational travel that previously was authorized under § 515.565(a) and § 515.565(b), respectively, where the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to September 30, 2026.

Effective September 30, 2026, OFAC amended § 515.584(h) to remove the authorization for banking institutions subject to U.S. jurisdiction to open and maintain accounts solely in the name of a Cuban national who is an independent private sector entrepreneur, as defined in § 515.340, for the purposes of conducting certain transactions authorized or exempt under the CACR. Unless separately authorized, banking institutions subject to U.S. jurisdiction are required to immediately block these funds and accounts, and will require a specific license from OFAC to unblock any such accounts or funds.

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.

Effective September 30, 2026, OFAC amended § 515.209 to reflect the expanded scope of activities for which the Secretary of State, as directed by the 2025 National Security Presidential Memorandum-5 (NSPM-5), may add entities or subentities to the CRL. Specifically, the Secretary of State may now add to the CRL any entities or subentities that are under the control of, or act for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel and with which direct or indirect financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba.

Additionally, the prohibition at 31 CFR § 515.209 previously prohibited persons subject to U.S. jurisdiction from engaging in "direct financial transactions" with entities or subentities on the CRL. Effective September 30, 2026, OFAC amended § 515.209 to also prohibit persons subject to U.S. jurisdiction from engaging in an "indirect financial transaction" with any entity or subentity on the CRL. See the prohibition at § 515.209 and FAQ 735 for more information regarding a "direct" and "indirect" financial transaction.

Further, to guard against evasion of the prohibition on direct or indirect transactions with entities or subentities on the CRL, OFAC also amended § 515.201(c) to add a prohibition on any transaction that has the purpose or effect of evading or avoiding prohibitions on direct or indirect transactions with entities or subentities on the CRL.

To account for these changes, OFAC amended the following general licenses that previously only excluded direct financial transactions with entities or subentities on the CRL to now also exclude indirect financial transactions with such entities: §§ 515.530 (powers of attorney); 515.534 (contingent contracts); 515.545 (information/informational materials); 515.560 (travel-related transactions); 515.561 (family visits); 515.564 (professional research); 515.565 (educational activities); 515.566 (religious activities); 515.567 (public performances); 515.572 (travel services); 515.573 (physical and business presence in Cuba); 515.574 (support for the Cuban people); 515.576 (private foundations or research or educational institutes); 515.577 (publishing); 515.578 (internet-based services); 515.581 (conferences in third countries); 515.584 (certain financial transactions); and 515.590 (certain grants, scholarships, and awards). For a complete description of what each general license authorizes and the restrictions that apply, see the aforementioned general licenses.

OFAC also amended 31 CFR § 515.421 to clarify that transactions ordinarily incident to licensed transactions do not include direct or indirect financial transactions with entities and subentities on the CRL if the terms of the applicable general or specific license expressly exclude such direct or indirect financial transactions.