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Financial Services Law Insights and Observations

OFAC sanctions Cuban officials

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

Financial Crimes

On August 13, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against two Cuban individuals and one Cuban entity under the Global Magnitsky Human Rights Accountability Act. According to OFAC, this is the third round of sanctions since protests started in Cuba in July, as the Department continues to impose sanctions on individuals and entities connected with actions to suppress peaceful, pro-democratic protests in Cuba (covered by InfoBytes here and here). As a result of the sanctions, all transactions by U.S. persons or in the U.S. that involve any property or interests in property of designated or otherwise blocked persons are generally prohibited. OFAC notes that its regulations generally prohibit U.S. persons from participating in transactions with these persons, which include “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods or services from any such person.”

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