Frequently Asked Questions

784. What types of telecommunications services are authorized under general license?

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

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… Read more

790. Are persons subject to U.S. jurisdiction engaging in authorized transactions permitted to enter into arrangements with Cuban state-owned entities, such as ETECSA?

Individuals or entities subject to U.S. jurisdiction engaging in authorized transactions, either pursuant to a general or specific license, may engage with Cuban state-owned entities as authorized by the OFAC license. For example, a U.S. company engaging in authorized telecommunications-related… Read more

768. What does the regulatory term "cash in advance" mean?

The regulatory interpretation of "cash in advance," which describes one of the permissible payment and financing terms for authorized exports and reexports of agricultural commodities, is "cash before transfer of title and control." For the full text, see 31 CFR § 515.533 …

786. Is "peering" — an arrangement of traffic exchange between internet networks — authorized by the CACR?

Yes. For example, a U.S. company could enter into a peering arrangement with ETECSA, the Cuban telecommunications provider, for the provision of internet services. See § 515.542(b) . …

772. Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S. jurisdiction engaged in authorized travel to Cuba?

Yes. See 31 CFR § 515.560 . …

773. May persons subject to U.S. jurisdiction engaged in authorized travel to Cuba obtain travel insurance from a third-country vendor?

Yes. See 31 CFR § 515.560 . …

774. May U.S. insurers issue policies and pay claims related to group health, life, and travel insurance on behalf of third-country nationals traveling to or within Cuba?

Yes, provided that the insurance policy is a global policy, and not specific to the third-country national’s travel to or within Cuba. Section 515.580 of the CACR authorizes persons subject to U.S. jurisdiction to issue or provide global health, life, or travel insurance policies for individuals… Read more

777. May persons subject to U.S. jurisdiction provide certain insurance-related services (such as cargo or hull insurance, or reinsurance) to persons subject to U.S. jurisdiction who are engaging in authorized activity in Cuba?

Where the provision of insurance-related services is directly incident to activity authorized by general or specific license, then the provision of such services is authorized as well. For example, § 515.566 of the CACR authorizes travel and travel-related transactions directly incident to engaging… Read more

782. If a foreign vessel is traveling to the United States via Cuba with cargo destined for the United States, may goods remain aboard the vessel for delivery to the United States while the vessel is docked in a Cuban port, and may that vessel and its cargo then enter the United States without being subject to the 180-day rule or the goods/passengers-on-board rule?

Yes, provided that no other factors trigger the 180-day rule or the goods/passengers-on-board rule. For example, no goods may be unloaded in Cuba other than goods that would be designated as EAR99 or controlled on the Commerce Control List only for anti-terrorism reasons if they had been exported… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence