OFAC Will Eliminate U-Turn Transactions For Cuba

What Is A U-Turn Transaction?

“31 CFR § 515.584(d), commonly known as the “U-turn” general license, authorizes U.S. banking institutions to process transactions originating and terminating outside the United States provided that neither the originator nor the beneficiary is a person subject to U.S. jurisdiction. This means that transactions related to third-country commerce involving Cuba or Cuban nationals may be processed in U.S. dollars through the U.S. financial system via financial institutions located in the United States that serve as intermediary banks.  

Additional FAQs below clarify that foreign branches or subsidiaries of U.S. banking institutions may act as the originating or beneficiary banks for such transactions.  

The examples below illustrate some of the transactions and parties that may use the U-turn general license: