Frequently Asked Questions

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

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

5. When screening for sanctions, how do I determine if I have a valid match to a name on one of OFAC's lists?

When attempting to verify or disqualify potential matches to individuals or entities on OFAC's sanctions lists, organizations should follow their own sanctions compliance policies and procedures for investigating potential matches. OFAC recommends that such procedures include the following steps… Read more

51. I believe OFAC may have blocked my funds. How can I get my funds released?

OFAC itself does not seize or hold blocked funds. To comply with U.S. sanctions regulations administered by OFAC, U.S. financial institutions are required to block or "freeze" certain property (e.g., funds, accounts) in their possession or control and report such blocked property to OFAC. Even… 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

59. Do I need an OFAC license to donate goods to sanctioned jurisdictions?

Some OFAC sanctions programs that broadly prohibit transactions involving an entire jurisdiction have exemptions or general licenses for certain donated goods, such as humanitarian articles, to relieve human suffering. For information on the exemptions and general licenses under a particular OFAC… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence