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Financial Services Law Insights and Observations

OFAC publishes Cuba FAQ

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

Financial Crimes

On September 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published frequently asked question (FAQ) 1090 related to Cuba sanctions. The FAQ clarifies that “U.S. persons send remittances to Cuba using digital payments,” and that OFAC’s general licenses are self-executing, meaning that if U.S. persons assess that their transactions fall within the scope of the authorizations, “they may execute such transactions without further assurance from OFAC. For transactions that do not fall within the scope of these authorizations, U.S. persons may apply for an OFAC specific license.” OFAC further noted that it “will prioritize specific license applications seeking authorization to enable remittances to flow more freely to the Cuban people via digital payments.”