Frequently Asked Questions

1087 … Yes.  Section 560.540(a)(1) of the ITSR authorizes the exportation to Iran of fee-based or no-cost cloud-based services incident to the exchange of communications over the internet.  In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-based software that is… Read more

1088 … A cloud-based service or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information… Read more

1089 … Yes, persons seeking to export software, services, or hardware to Iran or conduct other activities in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or other authorizations are encouraged to submit a specific… Read more

1090 … Yes, provided the underlying remittance transactions are authorized under 31 CFR § 515.570 of the Cuban Assets Control Regulations (CACR) and the digital payment service provider is a U.S.-registered money transmitter or other qualifying banking institution within the definition of that term… Read more

1091 … Yes. On September 23, G7 Leaders issued a statement condemning Russia's sham referenda and noting their collective readiness to impose further economic costs on Russia, and on individuals and entities both inside and outside of Russia that provide political or economic support for Russia's… Read more

1092 … Yes.  Multiple Russia-related sanctions authorities authorize sanctions against non-U.S. persons that provide goods, services, or other support for Russia’s military-industrial complex.  For example, OFAC may block any person determined to operate or have operated in the defense and related… Read more

735 … A person subject to U.S. jurisdiction traveling to Cuba to engage in an authorized family visit pursuant to 31 CFR § 515.561 is prohibited from engaging in direct financial transactions with the entities and subentities on the State Department’s Cuba Restricted List. As such, this traveler… Read more

736 … Yes, under certain circumstances. Persons subject to U.S. jurisdiction may engage in transactions in U.S. dollars in Cuba or with Cuban nationals with respect to activity that is authorized pursuant to the Cuban Assets Control Regulations (CACR) . For example, payments for telecommunications… Read more

737 … Yes. Persons subject to U.S. jurisdiction who are traveling to Cuba pursuant to one of the 12 authorized categories of travel may open and maintain bank accounts in order to access funds while located in Cuba for authorized transactions, and are authorized to close such accounts. For a… Read more

738 … Yes. Authorized travelers in Cuba are permitted to use credit or debit cards issued by a U.S. financial institution with respect to activity that is authorized pursuant to the CACR . Travelers are advised to check with their financial institution before traveling to Cuba to determine whether… Read more