Category: Regulatory

  • On Monday, OFAC published the following Iran-related Alert:

    and amended FAQ 156:

    156. How will U.S. and foreign financial institutions know that the Treasury Department has made such a finding pursuant to the Iranian Financial Sanctions Regulations?

    Answer

    On October 5, 2026, OFAC issued a notice alerting foreign financial institutions that continue to do business with Iran or its financial sector to the risk of sanctions under “Operation Economic Outcast.” If the Treasury Department makes a finding that a foreign financial institution knowingly engages in one or more sanctioned activities, as described in FAQ 155, and decides to impose strict condition(s), the Treasury Department will issue an order or a regulation that sets out the strict condition(s) to be imposed on the U.S. correspondent accounts or U.S. payable-through accounts of the relevant foreign financial institution, and will publish the order or regulation in the Federal Register. The Federal Register is available at www.govinfo.gov. If the Treasury Department decides to prohibit the opening or maintaining of U.S. correspondent accounts or U.S. payable-through accounts for a foreign financial institution, the Treasury Department will add the name of the foreign financial institution and publish it to the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List).

    Date Updated: October 5, 2026

  • The Determination, adding the automotive and rail sectors of the Iranian economy to the sectors OFAC can make designations under:

    and updated FAQ 831:

    831. How will OFAC define the sectors of the Iranian economy specified in Executive Order (E.O.) 13902 of January 10, 2020?

    Answer

    E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. On October 8, 2020, the Secretary of the Treasury identified the financial sector of the Iranian economy for additional sanctions under E.O. 13902. Iranian and non-Iranian persons operating in these sectors of the Iranian economy or sectors of the Iranian economy identified in the future could be subject to sanctions.

    OFAC expects to promulgate regulations that define the terms construction sector of the Iranian economy, mining sector of the Iranian economy, manufacturing sector of the Iranian economy, textiles sector of the Iranian economy, and financial sector of the Iranian economy consistent with the following:

    Construction sector of the Iranian economy: The term construction sector of the Iranian economy means the production, procurement, devising, framing, or arranging in Iran of parts or materials to fabricate, shape, or form buildings or structures, including the on-site development, assembly, or construction of residential, commercial, or institutional buildings in Iran. The term applies to engaging in new work, additions, alterations, maintenance, and repairs of residential, commercial, or institutional buildings. Persons such as for-sale builders, design-build firms, and project construction management firms in Iran may be considered as operating in this sector.

    Mining sector of the Iranian economy: The term mining sector of the Iranian economy means any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials from the Earth in Iran.

    Manufacturing sector of the Iranian economy: The term manufacturing sector of the Iranian economy means the creation in Iran of goods by manual labor or machinery that are for export from Iran or for sale within Iran. For the purposes of evaluating sanctions pursuant to E.O. 13902, persons in Iran manufacturing medicines, medical devices, or products used for sanitation, hygiene, medical care, medical safety, and manufacturing safety, including soap, hand sanitizer, ventilators, respirators, personal hygiene products, diapers, infant and childcare items, personal protective equipment, and manufacturing safety systems, solely for use in Iran and not for export from Iran, will not be considered to be operating in the manufacturing sector of the Iranian economy. Note that persons conducting or facilitating transactions for the provision, including any sale, of agricultural commodities, food, medicine, or medical devices to Iran will not be subject to sanctions under E.O. 13902.

    Textiles sector of the Iranian economy: The term textiles sector of the Iranian economy means the fiber synthesis, dyeing, weaving, knitting, or felting in Iran of textiles, including apparel, carpets, cloths, fabric, or related goods, that are for export from Iran.

    Financial sector of the Iranian economy: The term financial sector of the Iranian economy includes (1) all Iranian financial institutions as defined in Section 561.320 of the Iranian Financial Sanctions Regulations and (2) providers of economic or financial services in or involving Iran, including government-operated and private banks and financial institutions, savings banks, trust companies, credit card companies, investment banking services, foreign exchange services, money services businesses, payday lenders, mortgage companies, securities and commodities exchanges, securities brokers and dealers, commodity futures and options brokers and dealers, clearing corporations, asset managers, employee benefit plans, dealers in precious metals, stones, or jewels, and insurance companies, or any persons that are engaged in the business of accepting deposits, transferring funds, facilitating investment, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent, and any related activities, including the provision or receipt of goods, services, or technology to or involving the financial sector of the Iranian economy, as well as holding companies, affiliates, or subsidiaries of the foregoing, and other persons that, directly or indirectly, own or control providers of such services.

    Persons who knowingly engage in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the above-named sectors of the Iranian economy risk exposure to blocking sanctions pursuant to E.O. 13902. In addition, persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, persons designated pursuant to E.O. 13902 could themselves be designated. Furthermore, foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for such designated persons risk exposure to U.S. correspondent account or payable-through account sanctions.

    Date Updated: October 1, 2026

    Date Released

    December 7, 2020

  • Office of Financial Sanctions Implementation HM Treasury

    Frozen Assets Reporting 2026 

    Every year HM Treasury carries out a review of frozen assets to update its records and to capture any changes during the reporting period.  

    All persons that hold funds or economic resources owned, held, or controlled by a designated person are required to submit a report to OFSI by Monday 30th November 2026. 

    Your report must include details of all funds or economic resources frozen in the UK as well as those overseas, where these funds or economic resources are subject to UK financial sanctions legislation. Your report to OFSI must include the value of all such assets as of close of business on Wednesday 30 September 2026. Please ensure no reports are submitted before this date. 

    Where the funds or economic resources relate to shares, securities, or other debt or payment instruments, the GBP value should be provided in your report. 

    If you have previously reported information related to frozen assets to OFSI you are still required to submit a return to OFSI as part of the 2026 Frozen Asset Review. 

    All returns need to be made in the form of a completed template from the GOV.UK website to. Please note that the reporting template has been updated since last year. 

    and the guidance:

    ,
  • Publication of Regulatory Amendments; Publication of Cuba Sanctions Regulations; Issuance of New and Amended Cuba-related Frequently Asked Questions; Publication of Cuba-related OFAC Alert

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing a rule removing duplicative regulatory provisions and reorganizing multiple parts within the Code of Federal Regulations (CFR). Through these actions, OFAC is eliminating over 100 subparts from its chapter of the CFR, and making information regarding delegations of authority, recordkeeping, and reporting requirements, and the Paperwork Reduction Act easier to locate.

    Additionally, OFAC is amending the Iranian Transactions and Sanctions Regulations to incorporate Executive Order (E.O.) 13902 of January 10, 2020, “Imposing Sanctions With Respect to Additional Sectors of Iran.”

    OFAC is also publishing regulations to implement E.O. 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and Threats to the United States National Security and Foreign Policy.” Further, OFAC is amending the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR) to implement portions of the President’s foreign policy toward Cuba.

    These rules are currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on September 30, 2026.

    OFAC is also issuing five new, Cuba-related Frequently Asked Questions (FAQs 1271–1275) and 29 amended, Cuba-related Frequently Asked Questions.

    Finally, OFAC is publishing an OFAC Alert, “Expanded Sanctions Against Cuba,” which highlights increased sanctions risks for transactions involving Cuba.

    Here are the related files from the links above – the changes removing duplicative elements:

    the ITSR changes:

    CACR changes:

    Cuba FAQs 1271-1275:

    1275. How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect previous authorizations for professional meetings or conferences in Cuba? 

    Effective September 30, 2026, OFAC amended § 515.564 to eliminate the authorization related to the attendance at, or organization of, professional meetings or conferences in Cuba. Persons subject to U.S. jurisdiction are no longer authorized to attend or organize professional meetings or conferences in Cuba. OFAC is replacing that authorization with a limited wind down authorization for persons subject to U.S. jurisdiction who were in Cuba on September 30, 2026 pursuant to the former professional meetings authorization to engage in travel-related and other previously authorized transactions through October 30, 2026, provided they depart Cuba by October 30, 2026. In addition, OFAC is also authorizing persons to terminate and obtain refunds for travel and related transactions for trips consistent with the former professional meetings authorization until October 30, 2026.

    Released on Sep 29, 2026

    Cuba Sanctions

    1274. How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect educational travel to Cuba by persons subject to U.S. jurisdiction? 

    Effective September 30, 2026, OFAC narrowed the authorization for persons subject to U.S. jurisdiction, including U.S. academic institutions and their faculty, staff, and students, to engage in certain education-related transactions involving Cuba. Persons subject to U.S. jurisdiction that wish to engage in educational activities, including travel-related transactions, involving Cuba must now fit within one of these categories:

    • Educational Activities by Accredited U.S. Undergraduate or Graduate-Degree Granting Institutions: 31 CFR § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate-degree granting institutions, their students, and full time permanent employees to engage in certain educational activities, such as noncommercial research in Cuba specifically related to Cuba and for the purpose of obtaining a graduate degree, under the auspices of the academic institution without accompaniment by a representative from a sponsoring organization.
    • Educational Activities by Other Institutions: § 515.565(a)(2)authorizes certain educational activities not authorized under § 515.565(a)(1), such as certain educational exchanges sponsored by Cuban or U.S. secondary schools, provided that the activity takes places under the auspices of an organization subject to U.S. jurisdiction and that all travelers are accompanied by a representative of the sponsoring organization.

    Additionally, OFAC removed the previous authorization at § 515.565(b) for group people-to-people educational travel. 
    OFAC replaced these education-related authorizations with “grandfathering” provisions authorizing certain educational travel and group people-to-people educational travel that previously was authorized under § 515.565(a) and § 515.565(b), respectively, where the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to September 30, 2026.

    Released on Sep 29, 2026

    Cuba Sanctions

    1273. How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect previous authorizations related to Cuban private sector entrepreneurs? 

    Effective September 30, 2026, OFAC amended § 515.584(h) to remove the authorization for banking institutions subject to U.S. jurisdiction to open and maintain accounts solely in the name of a Cuban national who is an independent private sector entrepreneur, as defined in § 515.340, for the purposes of conducting certain transactions authorized or exempt under the CACR. Unless separately authorized, banking institutions subject to U.S. jurisdiction are required to immediately block these funds and accounts, and will require a specific license from OFAC to unblock any such accounts or funds.

    Released on Sep 29, 2026

    Cuba Sanctions

    1272. How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect those previously authorized “U-turn” transactions in which Cuba or a Cuban national has an interest? 

    Effective September 30, 2026, OFAC amended 31 CFR § 515.584(d)by removing the authorization for banking institutions subject to U.S. jurisdiction to process transactions that originate and terminate outside the United States, provided that neither the originator nor the beneficiary was a person subject to U.S. jurisdiction (the “U-turn general license”). Pursuant to 31 CFR § 515.584(d), banking institutions subject to U.S. jurisdiction are now only authorized to reject (vice block) such transactions.

    To account for the removal of the “U-Turn” authorization, OFAC also amended § 515.584(e) to remove the authorization for the unblocking and return of any transfer that would have been authorized pursuant to the prior “U-Turn” general license.

    Released on Sep 29, 2026

    Cuba Sanctions

    1271. How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect prohibitions related to the U.S. Department of State’s List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List or CRL)? 

    Effective September 30, 2026, OFAC amended § 515.209 to reflect the expanded scope of activities for which the Secretary of State, as directed by the 2025 National Security Presidential Memorandum-5 (NSPM-5), may add entities or subentities to the CRL. Specifically, the Secretary of State may now add to the CRLany entities or subentities that are under the control of, or act for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel and with which direct or indirect financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba.

    Additionally, the prohibition at 31 CFR § 515.209 previously prohibited persons subject to U.S. jurisdiction from engaging in “direct financial transactions” with entities or subentities on the CRL. Effective September 30, 2026, OFAC amended § 515.209 to also prohibit persons subject to U.S. jurisdiction from engaging in an “indirect financial transaction” with any entity or subentity on the CRL. See the prohibition at § 515.209 and FAQ 735 for more information regarding a “direct” and “indirect” financial transaction.

    Further, to guard against evasion of the prohibition on direct or indirect transactions with entities or subentities on the CRL, OFAC also amended § 515.201(c) to add a prohibition on any transaction that has the purpose or effect of evading or avoiding prohibitions on direct or indirect transactions with entities or subentities on the CRL.

    To account for these changes, OFAC amended the following general licenses that previously only excluded direct financial transactions with entities or subentities on the CRL to now also exclude indirect financial transactions with such entities: §§ 515.530 (powers of attorney); 515.534 (contingent contracts); 515.545 (information/informational materials); 515.560 (travel-related transactions); 515.561 (family visits); 515.564(professional research); 515.565 (educational activities); 515.566(religious activities); 515.567 (public performances); 515.572 (travel services); 515.573 (physical and business presence in Cuba); 515.574 (support for the Cuban people); 515.576 (private foundations or research or educational institutes); 515.577(publishing); 515.578 (internet-based services); 515.581(conferences in third countries); 515.584 (certain financial transactions); and 515.590 (certain grants, scholarships, and awards). For a complete description of what each general license authorizes and the restrictions that apply, see the aforementioned general licenses.

    OFAC also amended 31 CFR § 515.421 to clarify that transactions ordinarily incident to licensed transactions do not include direct or indirect financial transactions with entities and subentities on the CRL if the terms of the applicable general or specific license expressly exclude such direct or indirect financial transactions.

    Released on Sep 29, 2026

    the large batch of changed Cuba FAQs:

    794. What types of grants or awards in which Cuba or a Cuban national has an interest are authorized for persons subject to U.S. jurisdiction to provide? 

    Section 515.590 of the CACR authorizes the provision of certain grants, scholarships, or awards to Cuban nationals or in which Cuba or a Cuban national has an interest. Such grants, scholarships, or awards must relate to educational activities, certain humanitarian projects (as set forth in § 515.575 (b)), scientific research, or religious activities. This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.590. 

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    774. May U.S. insurers issue policies and pay claims related to group health, life, and travel insurance on behalf of third-country nationals traveling to or within Cuba? 

    Yes, provided that the insurance policy is a global policy, and not specific to the third-country national’s travel to or within Cuba. Section 515.580 of the CACR authorizes persons subject to U.S. jurisdiction to issue or provide global health, life, or travel insurance policies for individuals ordinarily resident in a country outside of Cuba who travel to or within Cuba, regardless of whether the insurance policy is issued only to that individual or to a group, such as to all employees of a particular company. For instance, a U.S. insurer may pay medical claims pursuant to a group health insurance policy to or on behalf of a covered third-country national injured while traveling in Cuba. However, this provision does not authorize a person subject to U.S. jurisdiction to issue an insurance policy that is specific to travel to Cuba. A separate provision of the CACR, § 515.560, authorizes the provision of health, life, and travel insurance-related services that are specific to Cuba for authorized U.S. travelers. However, please note that § 515.560 excludes from the authorization at § 515.560(c)(2) the lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210, as well as any direct or, effective September 30, 2026, indirect financial transactions with any entity or subentity on the State Department’s Cuba Restricted List. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. 

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    766. What types of payment or financing terms may be utilized for authorized exports and reexports of items other than agricultural commodities to Cuba? 

    Section 515.533(a) of the CACR does not restrict payment and financing terms for exports of items from the United States or reexports of 100 percent U.S-origin items from a third country, other than agricultural commodities. Examples of permissible payment and financing terms for authorized exports and reexports that are not agricultural commodities include: payment of cash in advance; sales on an open account; and financing by U.S. or third-country financial institutions.

    OFAC has issued a general license authorizing banking institutions to provide financing for such authorized exports or reexports of items other than agricultural commodities, including issuing, advising, negotiating, paying, or confirming letters of credit (including letters of credit issued by a financial institution that is a national of Cuba), accepting collateral for issuing or confirming letters of credit, and processing documentary collections. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.584(f). With the exception of transactions related to exports or reexports of medicines or medical supplies, items associated with the provision of telecommunications and internet services for the Cuban people, or items associated with air and sea operations that support permissible travel, cargo, or trade, the general license at § 515.584(f) excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct and indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    765. May persons subject to U.S. jurisdiction open an office in Cuba? 

    Pursuant to 31 CFR § 515.573, persons subject to U.S. jurisdiction may establish and maintain a physical presence, such as an office, warehouse, or retail outlet, in Cuba to engage in transactions authorized by or exempt from the CACR in the following categories: entities engaging in non-commercial activities authorized by section 515.574 (support for the Cuban people); entities engaging in humanitarian projects set forth in section 515.575(b) (humanitarian projects); private foundations or research or educational institutes engaging in transactions authorized by § 515.576; news bureaus; exporters of certain goods authorized for export or reexport pursuant to 31 CFR §§ 515.533 and 515.559; entities providing mail or parcel transmission services; providers of telecommunications or internet-based services; entities organizing or conducting certain educational activities; religious organizations; and providers of carrier and certain travel services. These persons may employ Cuban nationals in Cuba as well as persons subject to U.S. jurisdiction in Cuba (and such persons may maintain a domicile in Cuba). These persons may open and maintain bank accounts to facilitate authorized transactions. 31 CFR § 515.573 excludes from the authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.573. Persons subject to U.S. jurisdiction that do not meet the terms of the general license may apply to OFAC for a specific license. Such applications will be reviewed on a case-by-case basis. Additional authorizations from the Cuban government may also be required.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    761. Can U.S. trade delegations travel to Cuba? 

    Trade delegations are authorized to travel to Cuba only if each member of the delegation meets the criteria of an applicable general license authorizing travel to Cuba or has obtained a specific license from OFAC. Authorized trade delegations generally fall under one of two general licenses for travel authorization: either (1) 31 CFR § 515.533(c)(1), which authorizes travel-related and other transactions incident to the exportation of certain authorized goods from the U.S. to Cuba, specifically the conduct of “market research, commercial marketing, sales or contract negotiation, accompanied delivery, installation, leasing, servicing, or repair in Cuba of items consistent with the export or reexport licensing policy of the Commerce Department,” or (2) 31 CFR § 515.564(a)(1), which authorizes transactions related to professional research in Cuba. Both general licenses exclude from the authorizations lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  In addition, the general license related to professional research in Cuba excludes from its authorization direct or, effective September 30, 2026, indirect financial transactions with entities or subentities identified on the State Department’s Cuba Restricted List.  For a complete description of the scope of this prohibition, see 31 CFR § 515.209.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    760. How do U.S. companies know if a Cuban counterpart is affiliated with an entity or subentity on the Cuba Restricted List? 

    The names of the entities and subentities that the State Department identifies as under the control of, or acting for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel and with which direct or indirect financial transactions would disproportionally benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba are published on the Cuba Restricted List (CRL), which is available on the State Department’s website and in the Federal Register (updates to the CRL will also be published in the Federal Register).  Entities or subentities that are owned or controlled by another entity or subentity on the CRL are not treated as restricted unless also specified by name on the CRL.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    758. Is Cuba open for U.S. business and investment? 

    Persons subject to U.S. jurisdiction are prohibited from doing business or investing in Cuba unless authorized by OFAC.  An OFAC general license authorizes, subject to certain conditions and limitations, the exportation from the United States, and the reexportation from third countries, of items to Cuba where the exportation or reexportation is licensed or otherwise authorized by BIS.  See 31 CFR § 515.533(a). BIS currently authorizes certain categories of items to be exported or reexported to Cuba. In addition, OFAC currently generally licenses the establishment of a business presence or physical presence in Cuba for certain types of entities or persons.  See 31 CFR § 515.573. The general licenses for the establishment of a business presence or physical presence in Cuba exclude from the authorizations direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

    Updated on Sep 29, 2026

    Cuba Sanctions

    757. Are U.S. banking institutions authorized to process “U-turn” transactions in which Cuba or a Cuban national has an interest? 

    No. Effective September 30, 2026, banking institutions subject to U.S. jurisdiction are prohibited from processing “U-turn” transactions, i.e., funds transfers originating and terminating outside the United States, where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction. However, banking institutions subject to U.S. jurisdiction are authorized pursuant to 31 CFR § 515.584(d) to reject (vice block) such “U-turn” transactions.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    756. May a person subject to U.S. jurisdiction utilize online payment platforms to facilitate or process authorized transactions involving Cuba or a Cuban entity? 

    Yes. Subject to certain exceptions, transactions that are ordinarily incident to an authorized transaction are permitted. See the examples in 31 CFR § 515.421. Such transactions may include use of online payment platforms to facilitate authorized transactions. Authorized transactions ordinarily incident to licensed transactions exclude any direct or, effective September 30, 2026, indirect financial transaction with Cuba Restricted List (CRL)entities, as well as lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210, if the terms of the applicable general or specific license expressly exclude such transactions. See 31 CFR § 515.421(5)-(6). Also, 31 CFR § 515.421 tfurther notes that a transaction relating to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the CRL is not authorized as an ordinarily incident transaction where the terms of the general or specific license expressly exclude any such transactions. For a complete description of the scope of transactions ordinarily incident to a licensed transaction and the restrictions and exceptions that apply, see 31 CFR § 515.421.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    754. Is the U.S. originating bank, U.S. intermediary bank, or U.S. beneficiary bank required to independently verify that a person subject to U.S. jurisdiction is not engaging in a direct or indirect financial transaction as defined in § 515.209 when processing Cuba-related transactions? 

    No. To the extent the transaction involves an entity or subentity on the Cuba Restricted List, a financial institution can rely on the statements of its customer or information available to them in the ordinary course of business that the transaction is authorized unless it knows or has reason to know the transaction is not authorized. A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures with respect a transaction involving Cuba or a Cuban national and which may be authorized pursuant to the Cuban Assets Control Regulations.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    748. May U.S. banks open and operate accounts for Cuban nationals present in Cuba? 

    Yes. Section 515.584(h) of the CACR contains a general license that allows banking institutions to open and maintain bank accounts in the United States solely in the name of a Cuban national located in Cuba, to receive payments in the United States for transactions authorized pursuant to, or exempt from the prohibitions of, the CACR and to remit such payments back to Cuba, including through an online payment platform. For example, an author who is a Cuban national located in Cuba may open an account with a bank in the United States to receive payments for sales of their book.

    On September 30, 2026, OFAC amended § 515.584 to remove the authorization for U.S. banking institutions to open and maintain an account solely in the name of a Cuban national who is an independent private sector entrepreneur (as defined in 31 CFR § 515.340) for the purpose of conducting authorized or exempt transactions. Unless separately authorized, banking institutions subject to U.S. jurisdiction are required to immediately block these funds and accounts, and will require a specific license from OFAC to unblock any such accounts or funds.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    745. May U.S. banks open and operate accounts for Cuban nationals lawfully present in the United States? 

    Yes.  Pursuant to section 515.571(a)(5) of the CACR, banking institutions are permitted to maintain accounts for certain Cuban nationals present in the United States in a non-immigrant status or pursuant to other non-immigrant travel authorization.  Although the account may remain open while the Cuban national is not in the United States, access to such accounts must be limited to periods during which the Cuban national is lawfully present in the United States.  For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR § 515.571(a)(5).

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    737. Are authorized travelers permitted to open bank accounts in Cuba?    

    Yes.  Persons subject to U.S. jurisdiction who are traveling to Cuba pursuant to one of the 12 authorized categories of travel may open and maintain bank accounts in order to access funds while located in Cuba for authorized transactions, and are authorized to close such accounts.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR §  515.560(c)(6). This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

    Updated on Sep 29, 2026

    Cuba Sanctions

    736. May the U.S. dollar be used to conduct transactions in Cuba or with Cuban nationals? 

    Yes, under certain circumstances. Persons subject to U.S. jurisdiction may engage in transactions in U.S. dollars in Cuba or with Cuban nationals with respect to activity that is authorized pursuant to the Cuban Assets Control Regulations (CACR). For example, payments for telecommunications services in Cuba provided pursuant to 31 CFR § 515.542 may be provided in U.S. dollars. Further, the use of U.S. dollars for transactions that are exempt from the prohibitions of, or authorized by, the CACR is also allowed. For example, payments related to the importation or exportation of informational materials as defined in 31 CFR § 515.332, such as books or musical recordings, may be made in U.S. dollars.

    Please note that, effective September 30, 2026, banking institutions subject to U.S. jurisdiction are no longer authorized to process transactions in which Cuba or a Cuban national has an interest that originate and terminate outside the United States, even where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction (i.e., “U-turn” transactions). Such banking institutions are now only authorized to reject (vice block) these transactions.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    735. What would constitute What are examples of a direct or indirect financial transactions with an entity or subentity on the State Department’s Cuba Restricted List (CRL) prohibited by 31 CFR § 515.209? What are some examples of this prohibited conduct?  

    Section 515.209 prohibits persons subject to U.S. jurisdiction from engaging in a direct or, effective September 30, 2026, an indirect financial transaction with entities and subentities on the CRL. A person engages in a direct financial transaction by either acting as the originator on a transfer of funds whose ultimate beneficiary is on the CRL or as the ultimate beneficiary on a transfer of funds whose originator is an entity or subentity on the CRL, including a transaction by wire transfer, credit card, check, or payment of cash. A person engages in an indirect financial transaction by participating in a transfer of funds despite not acting as an originator or ultimate beneficiary of that funds transfer, where either the originator or the ultimate beneficiary is an entity or subentity on the CRL, including a transaction by wire transfer, credit card, check, or payment of cash. This definition of “indirect financial transaction” is unique to the Cuban Assets Control Regulations and should not be interpreted to apply to other OFAC programs.
    Below are some examples of direct and indirect financial transactions that 31 CFR § 515.209 would prohibit.

    Direct Financial Transactions

    1. A person subject to U.S. jurisdiction is traveling to Cuba to engage in an authorized family visit pursuant to 31 CFR § 515.561. The traveler books and pays for a hotel room directly with a hotel included on the CRL. This is a prohibited direct financial transaction because the traveler is a person subject to U.S. jurisdiction who would be the originator of a transfer of funds (i.e., payment for the room) whose ultimate beneficiary would be a hotel that is on the CRL.
    2. An individual working for a church subject to U.S. jurisdiction is interested in establishing a physical presence in Cuba pursuant to 31 CFR § 515.573(d)(3). The individual signs a new contract directly with a real estate company on the CRL to rent a location for the church’s physical presence, and the church begins making rent payments shortly thereafter. This is a prohibited direct financial transaction because the church is a person subject to U.S. jurisdiction who would be originating a transfer of funds (i.e., rent payments) whose ultimate beneficiary would be an entity on the CRL.
    3. A person subject to U.S. jurisdiction is traveling to Cuba to engage in professional research pursuant to 31 CFR § 515.564(a). The traveler books a stay a hotel that is on the CRL through a travel agency that is not subject to U.S. jurisdiction. The traveler pays for the trip, including for the room at the hotel, through the travel agency so that the traveler pays the travel agency, which in turn pays the Cuban entities, including the hotel. This is a prohibited direct financial transaction because the traveler is a person subject to U.S. jurisdiction who would be originating a transfer of funds (i.e., payment for the room) whose ultimate beneficiary would be an entity on the CRL.

    Indirect Financial Transactions

    1. A Cuban beverage manufacturer on the CRL seeks to pay for goods provided by a fruit supply company that is not subject to U.S. jurisdiction. The payment is routed to the fruit supply company’s bank via a U.S. correspondent bank. This is a prohibited indirect financial transaction because the U.S. bank is acting as an intermediary in a transfer of funds that originates from an entity on the CRL.
    2. A U.S. banking institution processes a payment from a non-U.S. person tourist for goods at a Cuban store on the CRL. This is a prohibited indirect financial transaction because the U.S. banking institution is acting as an intermediary in a transfer of funds where the ultimate beneficiary is an entity on the CRL.
    3. A U.S. banking institution processes a payment from a non-U.S. person tourist to a Cuban hotel on the CRL. This is a prohibited indirect financial transaction because the U.S. banking institution is acting as an intermediary in a transfer of funds where the ultimate beneficiary is an entity on the CRL.

    Please note that § 515.201(c) also prohibits any transaction for the purpose or which has the effect of evading or avoiding § 515.209’s prohibition on engaging in a direct or indirect financial transaction with entities or subentities on the CRL.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    734. What is the Cuba Restricted List and how does it impact Cuba-related transactions? 

    The State Department publishes a list of entities and subentities that the Secretary of State has determined are under the control of, or act for, on behalf of, or for the benefit of the Cuban military, intelligence, or security services or personnel, and with which direct or indirect financial transactions would disproportionately benefit the Cuban military, intelligence, or security services or personnel at the expense of the Cuban people or private enterprise in Cuba. This list is called the Cuba Restricted List (CRL), and is available on the State Department’s website at https://www.state.gov/division-for-counter-threat-finance-and-sanctions/cuba-restricted-list.

    The Cuban Asset Control Regulations (CACR) prohibit any direct or, effective September 30, 2026, indirect financial transaction with entities and subentities on the CRL. For a complete description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209. Please see FAQ 735 for additional information regarding a “direct financial transaction” and “indirect financial transaction.” Please see FAQ 1271 for additional information on the effect of OFAC’s September 30, 2026 amendment to the CACR on the CRL.

    The prohibition on direct or indirect financial transactions with entities and subentities on the CRL applies to the following general licenses: §§ 515.530 (powers of attorney); 515.534(contingent contracts); 515.545 (information/informational materials); 515.560 (travel-related transactions); 515.561 (family visits); 515.564 (professional research); 515.565 (educational activities); 515.566 (religious activities); 515.567 (public performances); 515.572 (travel services); 515.573 (physical and business presence in Cuba); 515.574 (support for the Cuban people); 515.576 (private foundations or research or educational institutes); 515.577 (publishing); 515.578 (internet-based services); 515.581 (conferences in third countries); 515.584(certain financial transactions); and 515.590 (certain grants, scholarships, and awards). For a complete description of what each general license authorizes and the restrictions that apply, see the aforementioned general licenses.

    The CACR also excludes from the scope of certain remittance-related general licenses any transactions relating to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the CRL. This restriction is distinct from the prohibition in § 515.209, which, for example, contains certain exceptions for pre-existing commercial engagements with CRL entities or subentities. See Note 2 to § 515.209, reinforcing this distinction. Specifically, OFAC excludes from the scope of certain general licenses any transaction relating to the collection, forwarding, or receipt of remittances involving any entity or subentity on the CRL, regardless of the existence of any pre-existing commercial engagements.

    In addition, § 515.421 of the CACR contains an interpretive provision for incidental transactions where OFAC has clarified that authorized transactions ordinarily incident to licensed transactions and necessary to give effect thereto exclude direct and indirect financial transactions with such entities or subentities on the CRL if the terms of the applicable general or specific license expressly exclude such direct or indirect financial transactions. Section 515.421 also clarifies that a transaction relating to the collection, forwarding, or receipt of remittances involving any entity or subentity identified on the CRL is not authorized as an ordinarily incident transaction where the terms of the general or specific license expressly exclude any such transactions. For a complete description of the scope of the interpretive provision and the restrictions and exceptions that apply, see 31 CFR § 515.421.

    Finally, effective September 30, 2026, § 515.201(c) prohibits any transaction that has the purpose or effect of evading or avoiding the prohibitions on direct or indirect transactions with entities or subentities on the CRL.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    724. Do travel service providers (such as travel agents and tour group operators) need to obtain specific licenses from OFAC to provide services for travel to Cuba? 

    No.  A general license authorizes persons subject to U.S. jurisdiction, including travel agents and tour group operators, to provide travel services in connection with authorized travel without the need for specific licenses from OFAC.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.572(a)(1). This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license further excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The provision of services related to travel for tourist activities or other unauthorized travel to Cuba remains prohibited. 

    Updated on Sep 29, 2026

    Cuba Sanctions

    717. Are there any spending limits for authorized U.S. travelers while in Cuba? 

    There is no specific dollar limit on authorized expenses; however, the Cuban Assets Control Regulations restrict persons subject to U.S. jurisdiction from engaging in direct or, effective September 30, 2026, indirect financial transactions with entities or subentities identified on the State Department’s Cuba Restricted List, with certain exceptions. See 31 CFR §§ 515.209 and 515.421.  Consistent with these authorizations and restrictions, authorized travelers may engage in transactions ordinarily incident to travel within Cuba, including payment of living expenses and the acquisition in Cuba of goods for personal consumption there. 31 CFR § 515.421 also  excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the State Department’s Cuba Prohibited Accommodations List to the extent prohibited by 31 CFR § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210. In addition, travelers are authorized to acquire in Cuba and import as accompanied baggage into the United States merchandise for personal use only; this authorization excludes imports into the United States of Cuban-origin alcohol or tobacco products.  OFAC considers “personal use” of an imported item to include giving the item to another individual as a personal gift, but not the transfer of the item to another person for payment or other consideration. Value imports remain subject to the normal limits on duty and tax exemptions for merchandise imported as accompanied baggage and for personal use. 

    Updated on Sep 29, 2026

    Cuba Sanctions

    710. What constitutes “exportation, importation, or transmission of information or informational materials” for generally authorized travel? 

    The general license at 31 CFR § 515.545(b)(1) authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to the exportation, importation, or transmission of information or informational materials.  This general license excludes from its authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full- time schedule in Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.545(b)(1).

    The general license at 31 CFR §515.545(b)(2) authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional media or artistic productions of information or informational materials for exportation, importation, or transmission, including the filming or production of media programs (such as movies and television programs), the recording of music, and the creation of artworks in Cuba, provided that the traveler is regularly employed in or has demonstrated professional experience in a field relevant to such professional media or artistic productions. This general license excludes from the authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List.  This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.545(b)(2).  The definition of “information and informational materials” may be found at 31 CFR § 515.332. 

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    709. What constitutes “activities of private foundations or research or educational institutes” for generally authorized travel? 

    Section 515.576 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to activities by private foundations or research or educational institutes with an established interest in international relations to collect information related to Cuba for noncommercial purposes, among other things.  This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license also excludes lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.576.  Additionally, 31 CFR § 515.573(d) authorizes private foundations or research or educational institutes engaging in transactions authorized by § 515.576 to establish a physical presence in Cuba, such as an office.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.573(a).

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    707. What constitutes “support for the Cuban people” for generally authorized travel and other transactions? 

    Section 515.574 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are intended to provide support for the Cuban people, which include activities of recognized human rights organizations; independent organizations designed to promote a rapid, peaceful transition to democracy; and individuals and non-governmental organizations that promote independent activity intended to strengthen civil society in Cuba.  In accordance with NSPM-5 as issued June 16, 2017, OFAC amended this general license on November 8, 2017, to require that each traveler utilizing this authorization engage in a full-time schedule of activities that enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities and that result in meaningful interactions with individuals in Cuba. This general license excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license also excludes lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba.  An entire group does not qualify for this general license merely because some members of the group qualify individually.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.574.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    706. What constitutes generally authorized travel under the travel-related category of “public performances, clinics, workshops, athletic and other competitions, and exhibitions”? 

    Section 515.567(a) of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to organization of and participation in amateur and semi-professional international sports federation competitions.  Transactions incident to the organization of such competitions include marketing related to those specific events in Cuba 

    OFAC will consider issuing specific licenses, on a case-by-case basis, for travel-related transactions and other transactions that are directly incident to participation in or organization of a public performance, clinic, workshop, athletic competition not covered by the general license in § 515.567(a), non-athletic competition, or exhibition in Cuba, subject to certain conditions.

    OFAC excludes from this authorization direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the Cuba Restricted List.  OFAC also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.567.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    705. Who is generally authorized to engage in travel-related transactions for “religious activities”? 

    Section 515.566 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to religious activities in Cuba.  All persons subject to U.S. jurisdiction, including religious organizations located in the United States and members and staff of such organizations, are generally authorized to engage in travel-related transactions that are directly incident to engaging in religious activities in Cuba provided, among other things, that the travel must be for the purpose of engaging in a program of religious activities.  This general license excludes direct and, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.  For a complete description of the scope of this prohibition, see 31 CFR § 515.210.  The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba.  For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.566.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    704. Can travelers engage in “people-to-people travel” to Cuba on an individual basis or as a part of a group? 

    No, persons subject to U.S. jurisdiction may not travel to Cuba to engage in “people-to-people” educational exchanges on an individual basis or, effective September 30, 2026, as part of a group.

    However, § 515.565(c) includes a grandfathering provision, authorizing certain educational travel that was previously authorized under § 515.565(a). Specifically, travelers may still engage in group people-to-people travel for educational activities consistent with the authorization for educational travel (31 CFR § 515.565(b)) as the authorization existed on June 30, 2025 (when the 2026 NSPM-5 was issued) provided the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to September 30, 2026. Any travel-related transactions under this grandfather provision, however, cannot involve either a direct or indirect financial transaction with entities or subentities on the State Department’s Cuba Restricted List. Please see FAQ 1274 for more information about how the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affected travel to Cuba for persons subject to U.S. jurisdiction.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    702. What constitutes “educational activities” for generally authorized travel and other transactions? 

    On September 30, 2026, OFAC amended 31 CFR § 515.565(a) to restore particular requirements for authorized educational activities related to Cuba. As of September 30, 2026, the requirements related to a person’s use of the educational activities- authorization depend on whether the person engaging in the activity is associated with an accredited U.S. undergraduate or graduate degree-granting academic institution.

    Effective September 30, 2026, § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate degree-granting academic institutions and their faculty, staff, and students, to engage in the travel-related transactions set forth in 31 CFR § 515.560(c) and such additional transactions as are directly incident to the six categories of educational activities enumerated in § 515.565(a)(1). Among other educational activities, this general license authorizes, subject to conditions outlined in § 515.565(a)(1), faculty, staff, and students at accredited U.S. undergraduate or graduate degree-granting academic institutions to participate in a structured educational program in Cuba or to teach at a Cuban academic institution, as well as authorizes Cuban scholars to engage in certain educational activities in the United States. For a complete description of authorized educational activities related to accredited U.S. undergraduate or graduate degree-granting academic institutions, and the restrictions that apply, see § 515.565(a)(1).

    Effective September 30, 2026, § 515.565(a)(2) authorizes persons subject to U.S. jurisdiction, including, for example, U.S. secondary schools, to engage in additional educational activities that are not authorized under § 515.565(a)(1), provided that: (1) any travel-related transactions pursuant to these authorizations take place under the auspices of an organization that is a person subject to U.S. jurisdiction (the “sponsoring organization”), and (2) all travelers are accompanied by a person subject to U.S. jurisdiction who is an employee, paid consultant, agent, or other representative of the sponsoring organization (subject to certain exceptions). These authorized transactions include the travel-related transactions set forth in § 515.560(c) and such transactions as are directly incident to the 12 categories of educational activities enumerated in § 515.565(a)(2). For example, under this general license, U.S. and Cuban universities may engage in academic exchanges and joint non-commercial academic research, and persons subject to U.S. jurisdiction may provide standardized testing services and certain internet-based courses to Cuban nationals. For a complete description of what this general license authorizes and the restrictions that apply, see § 515.565(a)(2).

    Effective September 30, 2026, OFAC further amended § 515.565 to remove the authorization for group people-to-people educational travel.

    Please note that the general license at § 515.565 excludes any direct or, effective September 30, 2026, indirect financial transaction with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see § 515.209. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    701. What constitutes generally authorized travel-related transactions for “professional research” in Cuba? 

    31 CFR § 515.564 (a)(1) contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional research in Cuba. Among other things, this general license authorizes, subject to conditions, professional research in Cuba relating to a traveler’s profession, professional background, or area of expertise.

    Effective September 30, 2026, OFAC amended § 515.564(a) to remove the previous license authorizing travel-related and other transactions incident to attendance at or organization of professional meetings or conferences in Cuba. However, specific licenses may be issued on a case-by-case basis for transactions related to such professional meetings. See FAQ 1275 for additional information on these changes.

    Please note that § 515.564 excludes from its authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see § 515.210. § 515.564 also excludes from its authorization any direct or indirect financial transaction with an entity or subentity identified on the State Department’s Cuba Restricted List. For a complete description of the scope of this prohibition, see § 515.209.

    The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule of professional research or a full-time schedule of attendance at, or organization of, professional meetings or conferences, respectively. An entire group does not qualify for the general license merely because some members of the group qualify individually. For a complete description of what these general licenses authorize and the restrictions that apply, see § 515.564.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    699. What constitutes “a close relative” for generally authorized family travel? 

    OFAC regulations generally authorize persons subject to U.S. jurisdiction and those sharing a dwelling with them as a family to visit a close relative in Cuba, including a close relative who is a Cuban national or a person ordinarily resident in Cuba, or to visit or accompany a close relative who is located in or traveling to Cuba pursuant to the authorizations in § 515.562 (official government business), § 515.563 (journalistic activity), § 515.564(a) (professional research), § 515.565(a)(1)(i) through (iv) and (vi) (educational activities), § 515.566 (religious activities), § 515.575 (humanitarian projects), or § 515.576 (activities of private foundations or research or educational institutes). A close relative is defined as any individual related to a person “by blood, marriage, or adoption who is no more than three generations removed from that person or from a common ancestor with that person.” For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.339and § 515.561. The authorizations contained within § 515.561 exclude direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209 or FAQ 735. 

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    696. Are authorized travelers who have initiated travel arrangements prior to the addition of an entity or subentity on the State Department’s Cuba Restricted List required to cancel their Cuba-related travel plans if their travel arrangements involve direct or indirect financial transactions with a listed entity or subentity? 

    Any travel-related arrangements that include direct or indirect financial transactions with entities and subentities that appear on the State Department’s Cuba Restricted List will continue to be permitted, provided that those travel arrangements were initiated prior to the State Department’s addition of the entity or subentity to the list. Once the State Department adds an entity or subentity to the Cuba Restricted List, new direct or, effective September 30, 2026, indirect financial transactions with the entity or subentity are prohibited, unless authorized by OFAC or exempt. For a complete description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.

    Date Updated: September 29, 2026

    Updated on Sep 29, 2026

    Cuba Sanctions

    695. What are the general travel authorizations in the Cuba program? 

    Travel-related transactions are permitted by general or specific licenses for certain travel related to the 12 categories of activities identified in 31 CFR § 515.560(a). Those travel-related transactions permitted by general license, subject to specified criteria and conditions, include: family visits; official business of the U.S. government, foreign governments, and certain intergovernmental organizations; journalistic activity; professional research and professional meetings; educational activities; religious activities; athletic competitions by amateur or semi-professional athletes or athletic teams; support for the Cuban people; humanitarian projects; activities of private foundations or research or educational institutes; exportation, importation, or transmission of information or information materials; and certain authorized export transactions. Each person relying on a certain general authorization must retain specific records related to the authorized travel transactions. See §§ 501.601 and 501.602 of the Reporting, Procedures and Penalties Regulations for applicable recordkeeping and reporting requirements.

    Effective September 30, 2026, OFAC amended § 515.564(a) to remove the authorization for persons subject to U.S. jurisdiction to travel to Cuba for purposes of attending or organizing professional meetings or conferences in Cuba. OFAC also amended § 515.565 to reinstate certain restrictions on authorized academic educational activities to require certain educational travel to occur under the auspices of an organization subject to the jurisdiction of the United States, and a representative of that sponsoring organization to accompany those travelers. Finally, OFAC removed the authorization for group people-to-people educational travel previously included in § 515.565. See FAQs 1274 and 1275 for more information on changes to travel-related authorizations under the Cuban Assets Control Regulations (CACR).

    Furthermore, the CACR includes a prohibition at § 515.209 that restricts certain direct and, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List (CRL). For a description of the scope of the prohibition on direct and indirect financial transactions with entities or subentities on the CRL, and the restrictions and exceptions that apply, see § 515.209.

    Additionally, § 515.210 prohibits any person subject to U.S. jurisdiction from lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property that the Secretary of State has identified as a property in Cuba that is owned or controlled by: the Cuban government; a prohibited official of the Government of Cuba, as defined in § 515.337; a prohibited member of the Cuban Communist Party, as defined in § 515.338; a close relative, as defined in § 515.339, of a prohibited official of the Government of Cuba, or a close relative of a prohibited member of the Cuban Communist Party, when the terms of the general or specific license expressly exclude such a transaction. The State Department maintains the Cuba Prohibited Accommodations List, which identifies the names, addresses, or other identifying details, as relevant, of properties identified as meeting such criteria.

    Updated: September 29, 2026

    Updated on Sep 29, 2026

    and the OFAC Alert:

  • Office of Financial Sanctions Implementation HM Treasury

    Update to FAQ 204 on licensing approach for designated Iranian banks

    OFSI has updated FAQ 204 on how it will assess licence applications involving the designated Iranian banks covered by HM Treasury’s licensing guidance.

    The FAQ now clarifies for the avoidance of doubt that this policy will be applied to all open licence applications.

    The updated FAQ:

    204. What criteria will OFSI be using in assessing applications? / How will OFSI apply the test?

    OFSI will assess applications on a case-by-case basis, against the relevant licensing grounds, alongside the criteria set out in this guidance and FAQs. For the avoidance of doubt, this policy will be applied to all open applications.

    The guidance is intended to give industry greater clarity on the narrower circumstances in which licences may be granted and the factors OFSI will take into account. 

    Under this guidance, licences for the banks covered by the guidance will only be granted where required by law, or in exceptional and urgent circumstances, such as where there is a risk to life, limb or environmental safety. 

    As such, activities that may be considered may include: 

    • risks to life or limb;
    • environmental safety;
    • essential insurance premiums and property management fees;
    • remuneration, allowances or pensions for existing employees;
    • tax, rent, mortgage and utility payments;
    • essential payments required by regulators;
    • essential steps to preserve assets; and
    • steps towards the wind-down of operations, including insolvency.

    Amended on: 29 Sep 2026

  • Claude explains the new Sanctions Penalties Regulations, and compares them to what existed beforehand:

    OFAC published a new regulation this week: 31 CFR Part 505, the Sanctions Penalties Regulations. It’s the kind of rule that sounds like a bigger deal in the announcement than it turns out to be once you’re actually inside it, which is exactly the sort of question this series exists to chase down. This post has two parts. The first walks through what the new rule actually says, since a straight read of a Federal Register final rule isn’t most people’s idea of a good time. The second, and more interesting, part is how Part 505 sits next to everything else OFAC already had on the books: what it consolidates, what it leaves completely alone, and one citation in the rule’s own text that doesn’t hold up.

    What OFAC Just Did, in Plain Terms

    Start with what actually changed. OFAC created a new, freestanding regulation gathering the enforcement procedures and penalty amounts for the two legal authorities behind the overwhelming majority of active US sanctions programs, the International Emergency Economic Powers Act (IEEPA) and the UN Participation Act (UNPA). It took effect the moment it published, September 25, 2026, with no notice-and-comment period, because Treasury treats this as a housekeeping rule about procedure rather than a change to what conduct actually gets penalized.

    Five pieces make up the new part:

    • General provisions, including a codified promise that OFAC will keep publishing civil penalty and settlement outcomes at least monthly (entity name, program, violation description, self-disclosure status, and amount; individuals appear only in aggregate, never by name).
    • Definitions, just IEEPA and OFAC itself. Everything else still comes from each program’s own regulation.
    • A reserved subpart, presumably held for future use.
    • The actual IEEPA penalty process: a Pre-Penalty Notice, a 30-day window to respond, a Penalty Notice if OFAC still finds a violation, referral to Justice if the person doesn’t pay, and the alternative “Finding of Violation” track OFAC uses when it wants a formal record without a fine attached.
    • UNPA penalties, which turn out to be much thinner than IEEPA’s. This part is criminal only: willful violations draw up to $1 million and 20 years, with no separate civil penalty structure of its own.

    The dollar figures that matter: IEEPA’s civil cap sits at $377,700 per violation, or twice the transaction value if that’s larger, and willful criminal violations top out at $1 million and 20 years. Voluntary self-disclosure earns a real discount, though how much depends on whether OFAC classifies the case as egregious or not. That distinction is worth getting right rather than compressing into a rule of thumb, so it’s covered properly in the next section.

    None of this is new law. OFAC says explicitly that no penalty amounts or enforcement standards changed, only where the rules describing them live. The practical effect on a compliance program today is close to nothing. Where it will eventually show up is in the individual program regulations, Russia’s, Iran’s, Syria’s, and so on, each of which currently carries its own near-identical penalty subpart. OFAC’s announcement says publication of Part 505 sets up the deletion of over 100 of those subparts as the individual programs get replaced with a one-line pointer to this new part instead.

    Where It Sits Next to Everything Else

    The useful way to think about Part 505 is as one layer of a stack that already had several other pieces, and it only touches one of them.

    The substance stays exactly where it was. Part 505 governs timing and paperwork. The actual judgment calls, the general factors OFAC weighs, and the base-penalty math still live in the Economic Sanctions Enforcement Guidelines at Appendix A to Part 501, which Part 505 cross-references rather than replacing (see 505.402(d)). This is also where the self-disclosure discount from the previous section actually gets worked out, and it’s more specific than a flat “cut in half.”

    For egregious cases, self-disclosure does cut the base penalty cleanly in half, from the full statutory maximum down to 50 percent of it. Non-egregious cases, which cover the majority of matters OFAC actually pursues, work differently. Without a self-disclosure, the base amount comes from a stepped schedule tied to transaction-value bands (under $1,000 gets a $1,000 base, $1,000 to $10,000 gets $10,000, and so on up through $200,000 and beyond, where it caps at the statutory maximum). With a self-disclosure, the base switches entirely to one-half of the actual transaction value, capped at $188,850. Those are two different quantities, not one number and its half. A $5,000 transaction with no self-disclosure lands a $10,000 schedule-based base; the same transaction disclosed voluntarily gets $2,500, a 75 percent reduction, not 50. In most of the schedule’s bands the gap is even wider, because the schedule rounds up to the next tier rather than tracking the real transaction value. Cuba is the one exception: it still runs on its own 2003 Cuba Penalty Schedule, where OFAC’s guidelines do describe the self-disclosure discount as a literal 50 percent reduction.

    TWEA-based programs run on an entirely separate, older track. Cuba, and whatever residual North Korea matters still reach back to the Trading with the Enemy Act rather than IEEPA, and that track is untouched by this rule. It lives in Part 501, Subpart D, and it differs from the new part in two ways worth knowing. The civil cap is lower, at $111,308 against IEEPA’s $377,700. And TWEA is the only one of OFAC’s penalty tracks that gives a respondent an in-house hearing before an administrative law judge, running roughly from Section 501.710 through Section 501.761, before a case becomes final agency action. Part 505 skips that step entirely: a Penalty Notice is final agency action, full stop, and the only recourse is federal district court.

    A few statutes never ran through IEEPA at all, and Part 505 leaves them alone too. The Foreign Narcotics Kingpin Designation Act (Part 598) carries the highest civil cap of any OFAC authority, $1,876,699 per violation. The material-support statute behind the Foreign Terrorist Organizations program (Part 597) caps at the greater of $99,703 or twice the blocked funds a financial institution failed to retain, and it runs on its own statute, 8 U.S.C. 1189, not IEEPA at all. Both keep their own dedicated procedures.

    AuthorityCFR homeCivil cap per violationDistinctive feature
    IEEPA / UNPA (new)Part 505$377,700, or twice the transaction value if greaterNo in-house hearing; a Penalty Notice is final agency action
    TWEA (Cuba today)Part 501, Subpart D$111,308The only track with an in-house hearing before an administrative law judge
    Kingpin ActPart 598, Subpart G$1,876,699Highest cap of any OFAC authority
    FTO / AEDPA (18 U.S.C. 2339B)Part 597, Subpart GGreater of $99,703 or twice blocked funds not retainedRuns on its own statute, not IEEPA
    Clean Diamond Trade ActPart 592, Subpart F$17,062Lowest cap of the five; see the note below

    One citation in Part 505’s own background section doesn’t hold up. It lists the Clean Diamond Trade Act’s penalties as sitting in “appendix A to 31 CFR part 501.” That’s not quite right. Appendix A does reference the CDTA’s $17,062 maximum, alongside the other four statutes, because all five share the same general factors and vocabulary that Appendix A defines. But the CDTA’s actual penalty regulations, the pre-penalty notice, response, and penalty imposition procedures, are codified separately at 31 CFR Part 592, Subpart F, the Rough Diamonds Control Regulations. It reads as though whoever drafted that background paragraph conflated “Appendix A mentions this number” with “Appendix A is where this regulation lives.”

    One more thing worth knowing, for what it’s worth: this isn’t the first tenant at address 505. The number previously housed the Transaction Control Regulations, covering certain offshore trade in strategic goods with the former Soviet Bloc, until OFAC removed it in 2011 after the underlying Trading with the Enemy Act authority over North Korea lapsed. It sat vacant for fifteen years before this rule moved back in.

    A Note on Sources

    Every dollar figure above comes from the current text of Appendix A to Part 501, cross-checked against OFAC’s January 2025 inflation-adjustment rule, the last one that actually changed anything. There was no 2026 adjustment: the October 2025 CPI-U data needed to calculate it was never produced because of the government shutdown, and OMB formally canceled the 2026 adjustment in Memorandum M-26-11. Every number in this post, including the ones written into Part 505 itself, is the same figure that has been in effect since January 2025.

    So, did OFAC change how sanctions penalties work, or just where they live? Mostly the latter. The dollar amounts, the general factors, and the self-disclosure math didn’t move. What moved is the address, and the promise that OFAC will eventually clean up a rulebook that currently says the same thing in more than a hundred places. Whether that promise gets kept on any particular timeline is, itself, a pretty good burning question for a future post.

  • Additionally, OFAC is amending the Terrorism List Governments Sanctions Regulations to implement changes resulting from the rescission of the designation of Syria as a State Sponsor of Terrorism.  Specifically, OFAC is removing and reserving a Syria-specific general license because the authorization is no longer necessary following the rescission.  

    Here are the amended regs:

  • The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is consolidating previously existing information regarding enforcement procedures and penalties, including the rights of U.S. persons being investigated for violations, that are currently located in individual parts of 31 CFR chapter V into a new part, the Sanctions Penalties Regulations.  Following publication of this part, OFAC will update parts within 31 CFR chapter V to replace existing penalties information with cross-references to the Regulations, resulting in the deletion of over 100 subparts from existing regulations.

    Here they are (I’ll spin up Claude to summarize and compare to what used to be later):

  • Office of Financial Sanctions Implementation HM Treasury

    How OFSI will assess licence applications involving designated Iranian banks

    OFSI has published a new FAQ explaining how it will assess licence applications involving the five designated Iranian banks covered by HM Treasury’s new licensing guidance.

    The FAQ confirms that applications will continue to be assessed on a case-by-case basis, but licences will generally only be granted where required by law or in exceptional and urgent circumstances, such as risks to life, environmental safety, essential regulatory payments, asset preservation, or the wind-down of operations.

    Here’s the Frequently Asked Question:

    204. What criteria will OFSI be using in assessing future applications? / how will OFSI apply the test?

    OFSI will assess applications on a case-by-case basis, against the relevant licensing grounds, alongside the criteria set out in this guidance and FAQs. The guidance is intended to give industry greater clarity on the narrower circumstances in which licences may be granted and the factors OFSI will take into account. 

    Under this guidance, licences for the banks covered by the guidance will only be granted where required by law, or in exceptional and urgent circumstances, such as where there is a risk to life, limb or environmental safety. 

    As such, activities that may be considered may include: 

    • risks to life or limb; 
    • environmental safety; 
    • essential insurance premiums and property management fees; 
    • remuneration, allowances or pensions for existing employees; 
    • tax, rent, mortgage and utility payments; 
    • essential payments required by regulators; 
    • essential steps to preserve assets; and 
    • steps towards the wind-down of operations, including insolvency.

    Added on: 24 Sep 2026

  • Office of Financial Sanctions Implementation HM Treasury

    The Office of Financial Sanctions Implementation (OFSI) has published new guidance today. With immediate effect, HM Treasury will apply a presumption of denial to licence applications made by the five designated Iranian banks listed below. Each application will continue to be considered on its individual facts.  

    • Bank Sepah 
    • Melli Bank plc 
    • Bank Saderat 
    • Persia International Bank 
    • Bank Tejarat 

    This means that licence applications involving these banks will generally be refused unless there are clear and compelling reasons to justify an exception. Further details on how this test will be applied will be set out in a FAQ soon. 

    In addition, OFSI will not renew the Iran Interim Basic Necessities General Licence INT/2025/7628424, which expires on 22 October 2026.  Following its expiry, transactions previously authorised under that General Licence will no longer be authorised unless permitted by another applicable general licence or by a specific licence issued by HM Treasury. 

    and the guidance:

    Guidance

    Presumption of Denial of Licence Applications for Designated Iranian banks

    Published 23 September 2026

    1. Context

    Iran’s nuclear programme continues to pose a serious threat to international peace and security. Following Iran’s non-compliance with the Joint Comprehensive Plan of Action, the UK implemented the snapback of UN Iran sanctions on 1 October 2025.

    The UK Government has been and will continue to apply economic pressure on Iran, alongside the US and other partners, to enable diplomacy that delivers a lasting and sustainable settlement. On 8 September 2026, the Foreign, Commonwealth and Development Office laid legislation tightening sanctions against Iran, including financial measures intended to reduce the Government of Iran’s access to the UK financial system and its ability to raise funds in support of its nuclear programme.

    On 16 June 2026, the Financial Action Task Force reminded jurisdictions of their obligations to address terrorist and proliferation financing risks emanating from Iran. The Government is determined to prevent the Iranian regime from exploiting the global economy and the UK financial system to advance its nuclear programme and wider destabilising activities.

    With immediate effect, OFSI will apply a presumption of denial to licence applications made by the designated Iranian banks listed below. Each application will continue to be considered on its individual facts.

    2. Banks in scope

    This policy applies to licence applications made by the following designated banks operating in the UK:

    • Bank Sepah
    • Melli Bank plc
    • Bank Saderat
    • Persia International Bank
    • Bank Tejarat

    These banks are designated under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019.

    3. Licensing approach

    HM Treasury may issue licences permitting activity otherwise prohibited by sanctions where an applicable licensing purpose exists and its criteria are met. It retains a discretion to refuse a request where licensing would be inappropriate, which includes where this would undermine the integrity or objectives of the sanctions regime.

    Applications from the banks listed above will therefore be presumed for denial unless the applicant demonstrates clear and compelling reasons for licensing the proposed activity, as outlined in paragraph 4 below. .

    Additionally, the current General Licence INT/2025/7628424 will not be renewed when it expires on 22 October 2026. Following its expiry, transactions previously authorised under that General Licence will no longer be authorised unless permitted by another applicable general licence or by a specific licence issued by HM Treasury.

    4. Activities that may be considered

    Under this policy, licences will only be granted to the above banks as required by law or in exceptional and urgent circumstances, such as risk to life, limb or environmental safety. OFSI will publish a further FAQ clarifying how it will apply this test.

    5. Conditions and limitations

    Applicants will need to demonstrate that one or more of the criteria in paragraph 4 above are met. Even where a licence is issued, this will only be granted to cover requirements at the most basic level.

    In addition, the strong presumption in considering such applications is that transactions may only take place within the UK. No licences will be issued for funds held by entities operating in the UK to be remitted back to Iran (directly or indirectly).

    Licences will only be issued to permit recordable and auditable transactions. No licences will be issued to permit payments in cash, nor will transfers be allowed from one designated bank to another. 

    6. Case-by-case assessment

    OFSI will continue to review each application on a case-by-case basis, but, unless the strict criteria above are met any application from these banks will ordinarily fall to be denied.  Should applicants consider that one of the criteria above are met, they should provide clear written evidence of their assertion when any licence application is made.

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