Frequently Asked Questions

766. What types of payment or financing terms may be utilized for authorized exports and reexports of items other than agricultural commodities to Cuba?

766 … Section 515.533(a) of the CACR does not restrict payment and financing terms for exports of items from the United States or reexports of 100 percent U.S-origin items from a third country, other than agricultural commodities. Examples of permissible payment and financing terms for authorized… Read more

767. What types of payment or financing terms may be utilized for authorized exports and reexports of agricultural commodities to Cuba?

767 … For such exports and reexports, only the following payment and financing terms may be used: payment of cash in advance, or financing by a banking institution located in a third country, subject to certain restrictions. This limitation is required by the Trade Sanctions Reform and Export… Read more

768. What does the regulatory term “cash in advance” mean?

768 … The regulatory interpretation of “cash in advance,” which describes one of the permissible payment and financing terms for authorized exports and reexports of agricultural commodities, is “cash before transfer of title and control.” For the full text, see 31 CFR § 515.533 . … What does the… Read more

769. What types of Cuban-origin goods are authorized for importation directly into the United States?

769 … Persons subject to U.S. jurisdiction authorized to travel to Cuba and persons subject to U.S. jurisdiction located in third countries may import into the United States as accompanied baggage merchandise acquired in Cuba provided that the merchandise is for personal use only. Please note that… Read more

770. What types of goods and services produced by independent private sector entrepreneurs are authorized for importation into the United States from Cuba pursuant to 31 CFR § 515.582?

770 … Pursuant to 31 CFR § 515.582 , certain goods and services produced by independent private sector entrepreneurs, as defined in 31 CFR § 515.340 , and as set forth in a list maintained by the State Department on its website , are authorized for importation. Persons subject to U.S. jurisdiction… 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?

771 … 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.… Read more

772. Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S. jurisdiction engaged in authorized travel to Cuba?

772 … Yes. See 31 CFR § 515.560 . … Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S. jurisdiction engaged in authorized travel to …

773. May persons subject to U.S. jurisdiction engaged in authorized travel to Cuba obtain travel insurance from a third-country vendor?

773 … Yes. See 31 CFR § 515.560 . … May persons subject to U.S. jurisdiction engaged in authorized travel to Cuba obtain travel insurance from a third-country vendor? …

774. May U.S. insurers issue policies and pay claims related to group health, life, and travel insurance on behalf of third-country nationals traveling to or within Cuba?

774 … Yes, provided that the insurance policy is a global policy, and not specific to the third-country national’s travel to or within Cuba. Section 515.580 of the CACR authorizes persons subject to U.S. jurisdiction to issue or provide global health, life, or travel insurance policies for… 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?

775 … 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… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence