Frequently Asked Questions

1175. Are services related to application programming interfaces (APIs) that are incident to the exchange of communications over the internet authorized for exportation or reexportation to Cuba pursuant to OFAC regulations?

Yes. Section 515.578(a)(1)(i) of the CACR authorizes the direct or indirect exportation or reexportation to Cuba, from the United States or by a person subject to U.S. jurisdiction, of certain services. Among these are API-related services incident to the exchange of communications over the… Read more

1176. What level of due diligence are internet-based service providers expected to conduct to determine whether the intended recipients of an export or reexport are prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party pursuant to 31 CFR § 515.578(b)(1)?

Section 515.578(b)(1) of the CACR excludes from authorization under 31 CFR 515.578(a)(1)-(3) the direct or indirect exportation or reexportation of services with knowledge or reason to know that such services are intended for a prohibited official of the Government of Cuba, as defined in 31 CFR §… Read more

1177. What internet-based services can be exported or reexported from the United States or by persons subject to U.S. jurisdiction to prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party?

Section 515.578(a)(4)(i) of the CACR authorizes the exportation or reexportation, directly or indirectly, from the United States or by a person subject to U.S. jurisdiction, to a prohibited official of the Government of Cuba, as defined in 31 CFR § 515.337 , a prohibited member of the Cuban… Read more

1178. Can a good be considered “produced by independent private sector entrepreneurs” for purposes of 31 CFR § 515.582 (authorizing the importation of certain goods and services produced by independent private sector entrepreneurs) if a Cuban state-owned entity is involved?

Section 515.582 of the CACR authorizes persons subject to U.S. jurisdiction to import certain goods and services produced by independent private sector entrepreneurs, as determined by the State Department and set forth on the State Department's Section 515.582 List . See FAQ 770 . In determining… Read more

1179. What type of small businesses are considered an “independent private sector entrepreneur” (as defined in 31 CFR § 515.340)?

Section 515.340 defines the term “independent private sector entrepreneur” to mean a Cuban national who is not a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party, and who is one or more of the following: (a) an owner, including a self-employed… Read more

1251. What does Executive Order (E.O.) 14404 of May 1, 2026, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to U.S. National Security and Foreign Policy," do?

E.O. 14404 takes additional steps with respect to the national emergency declared in E.O. 14380 of January 29, 2026, "Addressing Threats to the United States by the Government of Cuba." E.O. 14404 authorizes the imposition of sanctions by the Secretary of the Treasury and the Secretary of State on… Read more

1254. On May 7, 2026, the Department of State designated the Cuban entity Grupo de Administración Empresarial S.A. (GAESA) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with GAESA?

Generally, yes, but 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 wind down of transactions involving GAESA, or any entity in which GAESA owns, directly or indirectly, a 50… Read more

1253. What does Cuba-related General License (GL) 1, "Transactions Authorized Pursuant to the Cuban Assets Control Regulations," authorize?

On May 7, 2026, OFAC issued Cuba-related GL 1 , authorizing all transactions prohibited by E.O. 14404 where such transactions are authorized or exempt under the Cuban Assets Control Regulations, 31 CFR part 515 ( CACR ). GL 1 includes transactions authorized by either general or specific license… Read more

1256. Are all persons that operate or have operated in the five sectors of the Cuban economy identified in E.O. 14404 sanctioned by OFAC under E.O. 14404?

No. E.O. 14404 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, or the Secretary of State, in consultation with the Secretary of the Treasury, to impose blocking sanctions on any foreign person determined to operate or have operated in the following sectors of… Read more

1255. Are persons blocked pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, automatically blocked pursuant to the E.O. 14404?

No. Persons blocked or otherwise identified pursuant to the CACR are not automatically blocked pursuant to the E.O. 14404 . The CACR and E.O. 14404 are separate sanctions authorities. E.O. 14404 separately authorizes the imposition of blocking sanctions and certain less-than-blocking sanctions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence