Frequently Asked Questions

791. Are Cuban nationals located outside of Cuba still considered blocked?

… outside of Cuba and otherwise meets the requirements set forth in 31 CFR § 515.505 is generally licensed as an unblocked national. Additionally all persons subject to U.S. … to travel and maintenance within that country. For a complete description of what this general… Read more

753. Is a financial institution required to independently verify that an individual’s travel is authorized when processing Cuba travel-related transactions?

… the financial institution knows or has reason to know that the travel is not authorized by a general or specific license. The CACR requires persons subject to U.S. jurisdiction providing travel or carrier … authorizes the person to travel to Cuba. See 31 CFR §515… Read more

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?

… to facilitate authorized transactions. Authorized transactions ordinarily incident to licensed transactions exclude direct financial transactions with Cuba Restricted List entities, … Accommodations List to the extent prohibited by § 515.210 , if the terms of the applicable… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

… No. Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of … agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other… Read more

822. I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

… NIOC owns a 50 percent or greater interest, that would have been authorized pursuant to a general license in sections 560.530(a) or (b), 560.532, or 560.533 of the ITSR prior to CBI and … E.O. 13224, as amended. Additionally, transactions and activities authorized under specific… Read more

792. Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with Cuban nationals located outside of Cuba?

… or indirectly, of goods or services to or from Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.585 . Other general licenses may authorize persons subject to U.S. jurisdiction, including U.… Read more

722. May crew or other personnel involved in the operation of aircraft transporting authorized travelers to Cuba remain in Cuba along with the aircraft?

… The general license authorizing travel-related transactions incident to the exportation or … to the particular authorized temporary sojourn. For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR § 515.… Read more

1125. I am a creditor of the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or a PdVSA subsidiary. Do I need an OFAC license to negotiate the settlement of claims related to assets of the Government of Venezuela or PdVSA?

… Venezuela General License (GL) 42 generally authorizes transactions prohibited by the Venezuela Sanctions … seek a specific license for entry into that agreement. OFAC intends to implement a favorable licensing policy for… Read more

1118. As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related General License (GL) 13R authorize transactions that involve the payment of this exit tax?

… from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC. GL 13R … by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits,… Read more

728. What types of arrangements may airlines enter into with a Cuban national (individual or entity) to facilitate the provision of carrier services between the United States and Cuba?

… of carrier services by air is authorized. For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR § 515.572(a)(2)(ii) . … to such arrangements are also authorized (see 31 CFR § 515.421 ).Further, OFAC amended this… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence