GL 52C authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, "PdVSA Entities"), by… Read more
OFAC encourages anyone who is aware of possible violations of OFAC-administered sanctions to report them to OFAC through OFAC's Disclosure Portal . In considering any enforcement action, OFAC looks at the totality of the circumstances surrounding any possible violation, including whether a matter… Read more
The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity… Read more
Travel-related transactions are permitted by general or specific licenses for certain travel related to the 12 categories of activities identified in 31 CFR § 515.560(a) . Those travel-related transactions permitted by general license, subject to specified criteria and conditions, include: family… Read more
On September 30, 2026, OFAC amended 31 CFR § 515.565(a) to restore particular requirements for authorized educational activities related to Cuba. As of September 30, 2026, the requirements related to a person's use of the educational activities- authorization depend on whether the person engaging… Read more
31 CFR § 515.564 (a)(1) contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional research in Cuba. Among other things, this general license authorizes, subject to conditions, professional… Read more
No, persons subject to U.S. jurisdiction may not travel to Cuba to engage in "people-to-people" educational exchanges on an individual basis or, effective September 30, 2026, as part of a group. However, § 515.565(c) includes a grandfathering provision, authorizing certain educational travel that… Read more
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
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 ordinarily… Read more
Yes. Section 515.584(h) of the CACR contains a general license that allows banking institutions to open and maintain bank accounts in the United States solely in the name of a Cuban national located in Cuba, to receive payments in the United States for transactions authorized pursuant to, or exempt… Read more