Frequently Asked Questions

794. What types of grants or awards in which Cuba or a Cuban national has an interest are authorized for persons subject to U.S. jurisdiction to provide?

… scientific research, or religious activities. In accordance with NSPM-5, OFAC amended this general license to exclude from the authorization direct financial transactions with entities and … on the State Department’s Cuba Restricted List . For a complete description of what this… Read more

781. Do the exceptions to the 180-day rule authorize shipments to or from Cuba?

… No. The general licenses involving the 180-day rule only authorize certain vessels to enter a U.S. port … agency restrictions may apply. For a complete description of the 180-day rule and the general licenses and exemptions that apply, see 31 CFR §§ 515.206 , 515… Read more

765. May persons subject to U.S. jurisdiction open an office in Cuba?

… accounts to facilitate authorized transactions. In accordance with NSPM-5, OFAC amended this general license to exclude from the authorization certain direct financial transactions with entities and … on the State Department’s Cuba Restricted List . For a complete description of… Read more

788. What type(s) of business arrangements are telecommunications and internet-based service providers that are subject to U.S. jurisdiction authorized to establish in Cuba?

… Section 515.573 of the CACR contains a general license that authorizes certain persons subject to U.S. jurisdiction, including … an office, warehouse, classroom, or retail outlet. For a complete description of what this general license authorizes and the… Read more

737. Are authorized travelers permitted to open bank accounts in Cuba?

… and are authorized to close such accounts. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.560(c)(6) . In accordance with NSPM-5, OFAC amended this general license to exclude from the… Read more

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

… General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize … to provide certain services and software to Iranian students. These general licenses include: General License G (GL G) authorizes accredited… Read more

513. Do the prohibitions imposed pursuant to E.O. 13808 and subsequent Venezuela-related E.O.s also extend to entities owned 50 percent or more by the Government of Venezuela?

… In general, yes. These prohibitions apply to transactions related to the Government of Venezuela, … than 50% owned, but otherwise controlled, by the Government of Venezuela. Note, however, that General License 2 authorizes all transactions otherwise prohibited by… Read more

1124. I am a party seeking to enforce bondholder rights to the shares of CITGO Holding serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond, pending the outcome of ongoing litigation. How can I preserve or enforce my bondholder rights consistent with the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR)?

… for the PdVSA 2020 8.5 percent bond (see also OFAC Frequently Asked Question (FAQ) 1123 ; General License 42 and OFAC FAQ 1125 ). This non-enforcement policy governs OFAC sanctions only and does … sale. As noted in FAQ 1125 , parties that have negotiated a settlement agreement… Read more

574. Will foreign persons be subject to sanctions for doing business with the individuals or entities designated under E.O. 13661 or E.O. 13662, or blocked pursuant to OFAC’s 50 percent rule on April 6, 2018 as a result of such a designation?

… 542 and 545 , a transaction is not “significant” if U.S. persons would not require specific licenses from OFAC to participate in it. Therefore, activity authorized by Ukraine-/Russia-related General Licenses 12A and 13 , and occurring within the time period… Read more

679. Executive Order (E.O.) 13884 of August 5, 2019, “Blocking Property of the Government of Venezuela,” blocks all property and interests in property of the Government of Venezuela. What does this mean for the IV Venezuelan National Assembly seated on January 5, 2016 (“IV National Assembly”)?

… in opposition to the Maduro regime. On January 09, 2023, OFAC issued Venezuela-related General License 31B authorizing all transactions involving the IV National Assembly, its … directly or indirectly, by the Government of Venezuela). Effective January 09, 2023, General… Read more

Frequently Asked Questions

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