Frequently Asked Questions

771. May a person subject to U.S. jurisdiction provide training to a Cuban distributor or customer on the use of goods authorized for export to Cuba by the Department of Commerce?

Yes. OFAC considers the provision of training to persons in Cuba, including to Cuban nationals, on the use of items authorized for export or reexport to Cuba by the Department of Commerce to be ordinarily incident to the export or reexport of the item and therefore authorized by 31 CFR § 515.533(a… Read more

788. What type(s) of business arrangements are telecommunications and internet-based service providers that are subject to U.S. jurisdiction authorized to establish in Cuba?

Section 515.573 of the CACR contains a general license that authorizes certain persons subject to U.S. jurisdiction, including telecommunications and internet-based service providers, to establish a physical and business presence in Cuba to provide authorized telecommunications and internet-based… Read more

776. Are health, life, or travel insurance policies that are issued to a "group" (e.g., an employer and its employees) authorized by the CACR?

Section 515.580 of the CACR authorizes global health, life, or travel insurance policies covering individuals ordinarily resident in a country outside of Cuba traveling to Cuba. The policy may be issued to a group, such as all employees of a company. The "global" requirement means it cannot be… Read more

775. May U.S. insurers, either directly or through third-country subsidiaries, issue policies, or pay insurance or reinsurance claims related to non-U.S. persons providing goods or services that facilitate travel by third-country nationals from a third country to Cuba?

Other than certain global health, life, or travel insurance policies for individuals authorized by 31 CFR § 515.580 , absent specific authorization from OFAC, U.S. insurers and their subsidiaries are not permitted to issue policies, provide reinsurance coverage, or pay insurance or reinsurance… Read more

781. Do the exceptions to the 180-day rule authorize shipments to or from Cuba?

No. The general licenses involving the 180-day rule only authorize certain vessels to enter a U.S. port within 180 days after leaving a port or place in Cuba; they do not authorize any shipments to or from Cuba. Shipments to or from Cuba may be separately authorized under other provisions of the… Read more

699. What constitutes "a close relative" for generally authorized family travel?

OFAC regulations generally authorize persons subject to U.S. jurisdiction and those sharing a dwelling with them as a family to visit a close relative in Cuba, including a close relative who is a Cuban national or a person ordinarily resident in Cuba, or to visit or accompany a close relative who… Read more

696. Are authorized travelers who have initiated travel arrangements prior to the addition of an entity or subentity on the State Department's Cuba Restricted List required to cancel their Cuba-related travel plans if their travel arrangements involve direct or indirect financial transactions with a listed entity or subentity?

Any travel-related arrangements that include direct or indirect financial transactions with entities and subentities that appear on the State Department's Cuba Restricted List will continue to be permitted, provided that those travel arrangements were initiated prior to the State Department’s… Read more

709. What constitutes "activities of private foundations or research or educational institutes" for generally authorized travel?

Section 515.576 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to activities by private foundations or research or educational institutes with an established interest in international… Read more

706. What constitutes generally authorized travel under the travel-related category of "public performances, clinics, workshops, athletic and other competitions, and exhibitions"?

Section 515.567(a) of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to organization of and participation in amateur and semi-professional international sports federation competitions.… Read more

705. Who is generally authorized to engage in travel-related transactions for "religious activities"?

Section 515.566 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to religious activities in Cuba. All persons subject to U.S. jurisdiction, including religious organizations located in the… Read more

Frequently Asked Questions

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