Frequently Asked Questions

779 … The 180-day rule is a statutory restriction prohibiting any vessel that enters a port or place in Cuba to engage in the trade of goods or the purchase or provision of services there from entering any U.S. port for the purpose of loading or unloading freight for 180 days after leaving Cuba,… Read more

780 … Yes. OFAC has authorized by general license certain exceptions to these rules. If a vessel engages only in one or more of the following activities with Cuba, it will qualify for the general license and therefore will not be subject to the 180-day rule or the goods/passengers-on-board rule:… Read more

781 … 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… Read more

782 … 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… Read more

783 … The exceptions to the 180-day rule apply to each individual vessel that meets the requirements of the general license irrespective of any code-sharing arrangement. Thus, any shipping company may deploy a vessel in a broader shipping arrangement and, so long as the vessel meets the terms of… Read more

784 … 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-… Read more

785 … The general license at 31 CFR § 515.578 authorizes the provision of certain services incident to the exchange of communications over the internet, services to support the exchange of communications over the internet, and services related to certain authorized exports or reexports.  … Read more

786 … 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) . … Is “peering” — an arrangement of traffic exchange between internet networks — authorized by the …

787 … Yes. Section 515.578 authorizes the exportation or reexportation to Cuba of services incident to the exchange of communications over the internet. To the extent data caching services are incident to such exchanges of communications, the provision of such services is authorized. Section 515.… Read more

788 … 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-… Read more