Frequently Asked Questions

796. Are specific licenses still required for transactions relative to the administration of a Cuban estate?

796 … Section 515.523 of the Cuban Assets Control Regulations authorizes all transactions incident to the administration and distribution of the assets of a blocked estate of a decedent. All property distributed pursuant to 31 CFR § 515.523 is unblocked, provided that neither Cuba nor a Cuban… Read more

797. What types of projects would fall within the authorization in 31 CFR §515.575 for microfinancing projects?

797 … Among other things, the provision for microfinancing projects in section 515.575 of the Cuban Assets Control Regulations (CACR) authorizes the provision of certain financial services to unemployed, underemployed, and low-income Cubans who have little or no access to conventional banks or… Read more

798. If a person had applied for a specific license from OFAC before the CACR was revised but now believes that the proposed activity is authorized pursuant to a general license, does that person need to wait for his or her specific license application to be adjudicated?

798 … No. If persons meet the qualifications listed in the general license, then they do not need to wait for an official determination from OFAC regarding their specific license application. Persons who have determined they may proceed under a general license may wish to contact OFAC Licensing to… Read more

799. Is a person subject to U.S. jurisdiction allowed to purchase or lease real property in Cuba?

799 … Generally no, a person subject to U.S. jurisdiction is not authorized to purchase or lease real property in Cuba. The CACR prohibit any person subject to U.S. jurisdiction from purchasing or leasing property in Cuba unless authorized by OFAC. Section 515.573 of the CACR authorizes certain… Read more

800. May persons subject to U.S. jurisdiction import Cuban-origin pharmaceuticals into the United States?

800 … Section 515.547(b) of the CACR authorizes all transactions incident to obtaining approval from the U.S. Food and Drug Administration (FDA) of Cuban-origin pharmaceuticals. The general license includes discovery and development, pre-clinical research, clinical research, regulatory review,… Read more

801. May persons subject to U.S. jurisdiction provide services to Cuba or the Cuban government to support infrastructure maintenance and development in Cuba?

801 … Section 515.591 of the CACR authorizes persons subject to U.S. jurisdiction to provide Cuba or Cuban nationals (including the Cuban government and state-owned entities) with services related to developing, repairing, maintaining, and enhancing Cuban infrastructure that directly benefit the… Read more

802. May persons subject to U.S. jurisdiction provide mail or parcel delivery services to Cuba or Cuban nationals?

802 … With respect to the receipt or transmission of mail and parcels between the United States and Cuba, Section 515.542(a) of the CACR authorizes persons subject to U.S. jurisdiction to engage in all transactions, including payments, incident to such activities, provided that the importation or… Read more

501. What does General License 1C (GL 1C), “Authorizing Certain Transactions with the Federal Security Service,” authorize?

501 … GL 1C authorizes transactions with the Federal Security Service (a.k.a. Federalnaya Sluzhba Bezopasnosti) (a.k.a. FSB) that are ordinarily incident and necessary to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation,… Read more

502. What sanctions remain in place on the Federal Security Service following the issuance of GL 1C?

502 … GL 1C only authorizes certain transactions and activities with the Federal Security Service acting in its administrative and law enforcement capacities. The GL was issued in order to ensure that U.S. persons engaging in certain business activities in Russia that are not otherwise prohibited… Read more

503. Does GL 1C authorize the exportation of hardware or software directly to the Federal Security Service, or where the Federal Security Service is the end user of such hardware and software?

503 … No. GL 1C does not authorize the export of any goods, technology, or services directly or indirectly to the Federal Security Service or any other blocked person, except for the limited purposes of complying with rules and regulations administered by, and certain actions and investigations… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence