Frequently Asked Questions

749. In what ways can Cuban nationals lawfully present in the United States participate in the U.S. financial system?

749 … Certain Cuban nationals who have taken up residence in the United States on a permanent basis and who meet the requirements set forth in 31 CFR § 515.505(a) are licensed as unblocked nationals, and may participate fully in the U.S. financial system. See 31 CFR §§ 515.505(a)(1) and (d) .… Read more

750. If a Cuban national resident in the United States has applied to become a lawful permanent resident alien of the United States, does that individual have to apply to OFAC to be treated as an unblocked national?

750 … No. If a Cuban national has taken up residence in the United States and has applied to become a lawful permanent resident alien of the United States and has an adjustment of status application pending, then the Cuban national is considered unblocked and does not need to apply to OFAC to be… Read more

751. Should financial institutions apply for a specific license to unblock funds transfers or accounts which meet the conditions for unblocking set forth in 31 CFR §§ 515.505, or 515.584 (e)?

751 … The CACR include a general license authorizing banking institutions to unblock any account that had been previously blocked solely because of the interest therein of one or more persons now licensed as unblocked nationals. For a complete description of what this general license authorizes and… Read more

752. Do U.S. banking institutions need to apply for a specific license to release funds transfers or accounts previously blocked pursuant to the CACR that are now authorized by general license?

752 … If a transaction was previously blocked pursuant to the CACR at the time of the transaction, and the CACR was later amended to allow similar transactions, the earlier transaction is not unblocked unless the CACR amendments include a general license that unblocks previously blocked funds.… Read more

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

753 … No. A financial institution may rely on U.S. travelers to provide their certifications of authorized travel directly to the person providing travel or carrier services when processing Cuba travel-related transactions, unless the financial institution knows or has reason to know that the… Read more

754. Is the U.S. originating bank or U.S. beneficiary bank required to independently verify that a person subject to U.S. jurisdiction is not engaging in a direct financial transaction as defined in § 515.209 when processing Cuba-related transactions?

754 … No. To the extent the transaction involves an entity or subentity on the Cuba Restricted List , a financial institution can rely on the statements of its customer that the transaction is authorized unless it knows or has reason to know the transaction is not authorized. A financial… Read more

755. Is a U.S. or third-country financial institution required to independently verify that the underlying transactions giving rise to U.S. dollar monetary instruments presented for processing and payment pursuant to § 515.584(g) are authorized?

755 … No. A financial institution receiving U.S. dollar monetary instruments for processing and payment directly or indirectly (in the case of a U.S. banking institution) may rely on the institution having presented such monetary instruments as confirmation that the underlying transactions are… 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?

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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence