September 3, 2026: OFAC Update, Part 2: new version of Cuba General License 4


This is GL 4A (Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba):

What are the important differences? Let Claude explain:

Paragraph (c) – restructured and narrowed:

  • GL 4 had two exclusions: (c)(1) barred financial transfers to any blocked person except for taxes, fees, import duties, or permits/licenses/public utility services tied to paragraph (a) transactions; and (c)(2) barred unblocking of any property.
  • GL 4A drops (c)(1) entirely. The sole remaining exclusion is the unblocking prohibition (what was (c)(2)), now written as the whole of (c).

Practical effect (my reading, not stated in the text itself): By removing (c)(1)’s narrow carve-out, GL 4A appears to broaden the scope of authorized financial transfers to blocked persons. Under GL 4, such transfers were confined to taxes, fees, import duties, and permit/license/utility payments tied to official-business transactions. Under GL 4A, that specific limitation is gone – transactions otherwise meeting the “ordinarily incident and necessary” standard in (a) or (b) are no longer subject to that narrower financial-transfer restriction. The only thing GL 4A still expressly withholds is unblocking of property. 


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