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Financial Services Law Insights and Observations

OFAC Updates Cuba-Related FAQs


Federal Issues

On July 25, OFAC updated its list of frequently asked questions related to Cuba to clarify requirements applicable to persons subject to U.S. jurisdiction that are providing carrier or travel services to Cuba pursuant to 31 C.F.R. § 515.572. According to new FAQ 38, where such a person is providing travel or carrier services to a customer traveling to or from Cuba under a specific license, OFAC will consider the collection and retention of the traveler’s specific license number to be equivalent to collecting and retaining a physical or electronic copy of the specific license, as required by § 515.572(b)(1). The carrier or travel services provider must maintain a record of the specific license number or a copy of the license for at least five years. Revised FAQ 39 reiterates that authorized carrier or travel service providers must also retain a certification from each customer traveling to or from Cuba indicating the provision of the Cuban Assets Control Regulations that authorizes travel and the names and addresses of the individual travelers for at least five years from the date of the transaction.

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