Frequently Asked Questions

756. May a person subject to U.S. jurisdiction utilize online payment platforms to facilitate or process authorized transactions involving Cuba or a Cuban entity?

756 … Yes. Subject to certain exceptions, transactions that are ordinarily incident to an authorized transaction are permitted. See the examples in 31 CFR § 515.421 . Such transactions may include use of online payment platforms to facilitate authorized transactions. Authorized transactions… Read more

757. Are U.S. banking institutions authorized to process “U-turn” transactions in which Cuba or a Cuban national has an interest?

757 … Yes. Effective May 29, 2024, banking institutions subject to U.S. jurisdiction are authorized to process “U-turn” transactions, i.e., funds transfers originating and terminating outside the United States, provided that neither the originator nor the beneficiary is a person subject to U.S.… Read more

758. Is Cuba open for U.S. business and investment?

758 … Persons subject to U.S. jurisdiction are prohibited from doing business or investing in Cuba unless authorized by OFAC. An OFAC general license authorizes, subject to certain conditions and limitations, the exportation from the United States, and the reexportation from third countries, of… Read more

759. Does the prohibition in 31 CFR § 515.209(a) require US businesses engaged in the Cuban market and that may undertake direct financial transactions with entities included on the State Department’s Cuba Restricted List to terminate their Cuba-related business relationships pursuant to the regulatory amendments?

759 … Consistent with the Administration’s interest in not negatively impacting U.S. businesses for engaging in lawful commercial opportunities, most existing Cuba-related commercial engagements that include direct financial transactions with entities and subentities identified on the State… Read more

854. What does General License 38 authorize?

854 … On November 30, 2020, OFAC designated CEIEC pursuant to Executive Order (E.O.) 13692 for its role in undermining democracy in Venezuela. Concurrent with this action, OFAC issued Venezuela General License (GL) 38 (“Authorizing the Wind Down of Transactions Involving CEIEC”). GL 38 authorizes… Read more

855. How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?

855 … Pursuant to Section 12 of E.O. 13902 , the prohibitions of E.O. 13902 do not apply to transactions for the conduct of the official business of the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors thereof… Read more

856. How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?

856 … Transactions and activities involving Iranian financial institutions blocked under E.O. 13902 remain authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR… Read more

857. Do the prohibitions in Executive Order (E.O.) 13959, as amended, apply to purchases or sales of publicly traded securities of subsidiaries of entities listed on the Non-SDN Chinese Military-Industrial Complex Companies List (the “NS-CMIC List”)

857 … The prohibitions in E.O. 13959, as amended, apply to a subsidiary of a Chinese Military-Industrial Complex Company (CMIC) listed on the NS-CMIC List only if such subsidiary itself is publicly listed on the NS-CMIC List by Treasury pursuant to E.O. 13959, as amended, or identified in the Annex… Read more

859. What are “publicly traded securities” for purposes of Executive Order (E.O.) 13959, as amended?

859 … For purposes of E.O. 13959, as amended, the term “publicly traded securities” includes any “security,” as defined in section 3(a)(10) of the Securities Exchange Act of 1934, Public Law 73–291 (as codified as amended at 15 U.S.C. 78c(a)(10)), denominated in any currency that trades on a… Read more

860. For purposes of Executive Order (E.O.) 13959, as amended, what financial instruments are covered by the provision stating the prohibitions apply to “any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such” publicly traded securities?

860 … Examples of financial instruments covered by this provision include, but are not limited to, derivatives (e.g., futures, options, swaps), warrants, American depositary receipts (ADRs), global depositary receipts (GDRs), exchange-traded funds (ETFs), index funds, and mutual funds, to the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence