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Financial Services Law Insights and Observations

OFAC amends CACR to remove certain remittance-related general authorizations

Financial Crimes OFAC Department of Treasury Cuba Sanctions Of Interest to Non-US Persons

Financial Crimes

On October 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a final rule amending the Cuban Assets Control Regulations (CACR) “to further implement portions of the President’s foreign policy toward Cuba to deny the Cuban government access to funds in connection with remittances to Cuba.” Among other things, the final rule amends several general licenses to remove any transactions that involve entities or subentities identified on the State Department’s Cuba Restricted List (CRL) from the scope of certain remittance-related general authorizations. According to OFAC, the CRL is a list of “entities and subentities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba.” Additionally, the final rule also clarifies that transactions that relate to the collection, receipt or forwarding of remittances involving an identified entity or subentity are “not authorized as an ordinarily incident transaction where the terms of the general or specific license expressly exclude any such transactions.” In conjunction with the announcement of the final rule, OFAC also updated and issued several new Frequently Asked Questions. The final rule takes effect November 26, allowing for a 30-day implementation period in order to allow for technical implementation of the additional restrictions.

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