Frequently Asked Questions

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… Read more

E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of the… Read more

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… Read more

On October 5, 2026, OFAC issued a notice alerting foreign financial institutions that continue to do business with Iran or its financial sector to the risk of sanctions under “Operation Economic Outcast.” If the Treasury Department makes a finding that a foreign financial institution knowingly… Read more

Section 515.209 prohibits persons subject to U.S. jurisdiction from engaging in a direct or, effective September 30, 2026, an indirect financial transaction with entities and subentities on the CRL . A person engages in a direct financial transaction by either acting as the originator on a transfer… Read more

The U.S. government does not intend to target foreign persons, including FFIs, pursuant to  E.O. 14404  for engaging in transactions ordinarily incident and necessary to the divestment from or the wind down of transactions involving BICSA, or any entity in which BICSA owns, directly or indirectly,… Read more

No. GL 60A authorizes all transactions related to earthquake relief efforts in Venezuela under the Venezuela Sanctions Regulations, which includes payment of taxes, tolls, and fees to the Government of Venezuela connected with such relief efforts. Payments related to earthquake relief that are… Read more

The State Department publishes a list of entities and subentities that the Secretary of State has determined are under the control of, or act for, on behalf of, or for the benefit of the Cuban military, intelligence, or security services or personnel, and with which direct or indirect financial… Read more

Persons subject to U.S. jurisdiction are authorized to engage in transactions that establish mechanisms to provide commercial telecommunications services in Cuba or linking third countries and Cuba. Persons subject to U.S. jurisdiction are also authorized to engage in telecommunications-related… Read more

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… Read more