U.S. Tightens Cuba Sanctions to Counter Regime Repression
Press Statement
September 30, 2026
This week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published new Cuba Sanctions Regulations implementing President Trump’s Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and Threats to the United States National Security and Foreign Policy,” which invokes the International Emergency Economic Powers Act (IEEPA) to significantly broaden and sharpen sanctions and economic pressure on Communist Cuba, its repressive military and intelligence apparatus, subversive and terror networks, and financial enablers. Treasury also amended the longstanding Cuban Assets Control Regulations (CACR) to close loopholes the Cuban regime has long exploited to engage in sanctions evasion, enrich regime insiders, and fund dangerous subversive and military activities which threaten the national security of the United States. The Trump Administration remains committed to leveraging all available sanctions authorities to drive meaningful reform in Cuba, support the Cuban people’s aspirations for freedom, and hold accountable the individuals and entities that pose a threat to the national security of the United States.
Publication of Regulatory Amendments
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.
Link To Federal Register Document
Link One- OFAC Alert
Link Two
Link Three
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.
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.
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.
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.
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 CRL any 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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.
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.
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.
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.
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 § 515.339 and § 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.
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.
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.
