Frequently Asked Questions

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

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?

776 … 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… Read more

777. May persons subject to U.S. jurisdiction provide certain insurance-related services (such as cargo or hull insurance, or reinsurance) to persons subject to U.S. jurisdiction who are engaging in authorized activity in Cuba?

777 … Where the provision of insurance-related services is directly incident to activity authorized by general or specific license, then the provision of such services is authorized as well. For example, § 515.566 of the CACR authorizes travel and travel-related transactions directly incident to… Read more

778. Does a person subject to U.S. jurisdiction require an OFAC specific license to pay an insurance claim that arises from authorized activity in Cuba if the payment involves a Cuban national?

778 … Where the provision of insurance-related services is authorized by general license, either expressly or as a transaction ordinarily incident to a licensed transaction, this authorization extends to the payment or settlement of claims, including to a Cuban national. … Does a person subject to… Read more

779. What are the “180-day rule” and the “goods/passengers-on-board rule”?

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence