OFAC Publishes New Frequently Asked Questions Regarding Cuba-Related Sanctions

April 16, 2015

On April 16, Treasury’s Office of Foreign Assets Control (OFAC) released new and updated Frequently Asked Questions (FAQs) relating to the Cuban Assets Control Regulations (CACR).

Key takeaways from the updated FAQs for U.S. financial institutions include: 

  • the Cuba embargo remains in place and most transactions between the U.S. and Cuba continue to be prohibited;
  • they may process all transactions incident to the processing and payment of credit and debit cards transactions for third-country nationals traveling to, from, or within Cuba; and
  • foreign branches of U.S. banks may open and operate accounts for newly unblocked Cuban nationals in third countries; however all funds transfers to or from such an account involving Cuba or a national of Cuba (other than an unblocked national) must be authorized or exempt.
Previously, on January 15, 2015, in furtherance of the President’s December 17, 2014 announcement related to Cuba, OFAC had revised the CACR to ease certain restrictions and issued FAQs pertaining to those revisions. Our earlier memo discussing the revised CACR is available here. The April 16 FAQs update the January 15 FAQs.