1. Where can I find the amendments to the Cuban Assets Control Regulations (CACR)?
   

   Please see the Federal Register.
   

2. When are the most recent amendments to the CACR effective?
   

   The most recent amendments will become effective when published in the Federal Register on
   September 21, 2015. The immediately preceding amendments became effective on January 16,
   2015.
   

3. Are sanctions on Cuba still in place following the President’s announcement on December
   17, 2014?
   

   Yes, the Cuba embargo remains in place. Most transactions between the United States, or
   persons subject to U.S. jurisdiction, and Cuba continue to be prohibited, and OFAC continues to
   enforce the prohibitions of the CACR. These changes, effective on January 16 and September 21,
   2015, respectively, are targeted to further engage and empower the Cuban people by facilitating
   authorized travel to Cuba by persons subject to U.S. jurisdiction, certain authorized commerce,
   and the flow of information to, from, and within Cuba.
   

4. Is the Department of Commerce also amending its rules?
   

   Yes. The Department of Commerce’s Bureau of Industry and Security (BIS) in coordination with
   OFAC, is also amending its rules. The BIS amendments, among other things, authorize the
   export of certain items to Cuba to improve living conditions, support independent economic
   activity, improve the free flow of information, and facilitate authorized travel and commerce. For
   additional information, please see the BIS website at: http://www.bis.doc.gov.

II. Travel
For questions regarding travel and accompanied baggage between the United States and Cuba,

please see the specific guidance on OFAC’s webpage.

5. What are the travel authorizations in the Cuba program?
   

   OFAC has issued general licenses within the 12 categories of authorized travel for many travel-
   related transactions to, from, or within Cuba that previously required a specific license (i.e., an
   application and a case-by-case determination).
   

   Travel-related transactions are permitted by general license for certain travel related to the
   following activities, subject to criteria and conditions in each general license: 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; public performances, clinics, workshops, athletic and other
   competitions, and exhibitions; 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.
   

6. Do travelers who fall within the scope of a general license need to submit a written request
   to OFAC for permission to travel or conduct transactions?
   

   No. No further permission from OFAC is required to engage in transactions by a person who
   meets all criteria in a general license. Individuals wishing to engage in activities that may fall
   within the scope of a general license should review the relevant general licenses contained in the
   CACR to determine whether their travel-related transactions are covered by such general licenses.
   Persons subject to U.S. jurisdiction who wish to engage in any travel within the 12 categories of
   activities specified in the CACR that does not meet the requirements of a general license will
   need to apply for a specific license from OFAC.
   

7. Is travel to Cuba for tourist activities permitted?
   

   No. Consistent with the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA),
   travel-related transactions involving Cuba are only permitted for the 12 categories of activities
   identified in the CACR. Travel-related transactions for other purposes remain prohibited.
   

8. 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 (professional research),
   

   § 515.565(a)(1) through (4) and (6) (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, please see 31 CFR § 515.339 and § 515.561.

9. Who is generally authorized to engage in travel and travel-related transactions for
   “journalistic activity”?
   

   OFAC has issued an expanded general license that incorporates prior specific licensing policy
   and authorizes, subject to conditions, travel-related transactions and other transactions that are
   directly incident to journalistic activities in Cuba. Among other things, this general license
   authorizes, subject to conditions, full-time journalists, supporting broadcast or technical
   personnel, and freelance journalists to travel to Cuba. The traveler’s schedule of activities must
   not include free time or recreation in excess of that consistent with a full-time schedule. 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 this general license authorizes and the
   restrictions that apply, please see 31 CFR § 515.563.
   

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

    OFAC has issued an expanded general license that incorporates prior specific licensing policy
    and 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. The traveler’s schedule of activities must not
    include free time or recreation in excess of that consistent with a full-time schedule. 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 this general license authorizes and the
    restrictions that apply, please see 31 CFR § 515.564.
    

    OFAC has issued an expanded general license that incorporates prior specific licensing policy
    and authorizes, subject to conditions, travel-related transactions and other transactions that are
    directly incident to attending professional meetings in Cuba. Among other things, this general
    license authorizes, subject to conditions, attendance at professional meetings or conferences in
    Cuba relating to a traveler’s profession, professional background, or area of expertise, provided
    that the purpose of the meeting or conference is not the promotion of tourism in Cuba. Travel in
    this category is generally licensed provided that the traveler’s schedule of activities does not
    include free time or recreation in excess of that consistent with a full-time schedule. 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 this general license authorizes and the
    restrictions that apply, please see 31 CFR § 515.564.
    

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

    OFAC has issued an expanded general license that incorporates prior specific licensing policy
    and authorizes, subject to conditions, transactions, including travel-related transactions, that are
    related to certain educational activities involving Cuba or Cuban nationals. Among other things,
    this general license authorizes, subject to conditions, faculty, staff, and students at U.S. academic
    institutions and secondary schools to engage in certain educational activities in Cuba, Cuban
    scholars to engage in certain educational activities in the United States, and certain activities to
    facilitate licensed educational programs. U.S. and Cuban universities may engage in academic
    exchanges and joint non-commercial academic research under the general license. This provision
    also authorizes persons subject to U.S. jurisdiction to provide standardized testing services and certain internet-based courses to Cuban nationals. 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 this general license authorizes and the restrictions that apply, please see 31
    CFR § 515.565(a).

    12. Are secondary schools and secondary school students permitted to engage in travel-related
    transactions under the general license for “educational activities”?
    

    Yes. Educational exchanges sponsored by Cuban or U.S. secondary schools involving secondary
    school students’ participation in a formal course of study or in a structured educational program
    offered by a secondary school or other academic institution, and led by a teacher or other
    secondary school official, are authorized under this general license. For a complete description of
    what this general license authorizes and the restrictions that apply, please see 31 CFR
    

    § 515.565 (a)(6). This provision allows for participation of a reasonable number of adult
    chaperones to accompany the secondary school student(s) to Cuba.
    

    13. What constitutes “people-to-people travel” for generally authorized travel?
    

    OFAC has issued a general license that incorporates prior specific licensing policy and
    authorizes, subject to conditions, travel-related transactions and other transactions that are
    directly incident to people-to-people educational activities in Cuba. Among other things, this
    general license authorizes, subject to conditions, persons subject to U.S. jurisdiction to engage in
    certain educational exchanges in Cuba under the auspices of an organization that is a person
    subject to U.S. jurisdiction and sponsors such exchanges to promote people-to-people contact.
    Additionally, an employee, paid consultant, or agent of the sponsoring organization must
    accompany each group traveling to Cuba to ensure the full-time schedule of educational exchange
    activities, and the predominant portion of the activities must not be with individuals or entities
    acting for or on behalf of a prohibited official of the Government of Cuba, as defined in 31 CFR
    § 515.337, or a prohibited member of the Cuban Communist Party, as defined in 31 CFR
    

    § 515.338. For a complete description of what this general license authorizes and the restrictions
    that apply, please see 31 CFR § 515.565(b).
    

    14. What is an “organization” in the people–to-people context?
    

    In the people-to-people context, an organization is an entity subject to U.S. jurisdiction that
    sponsors educational exchanges that do not involve academic study pursuant to a degree program
    and that promote people-to-people contact. For a complete description of what this general
    license authorizes and the restrictions that apply, please see 31 CFR § 515.565(b).
    

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

    OFAC has issued an expanded general license that incorporates prior specific licensing policy
    and 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. 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, please see 31 CFR § 515.566.

    16. What constitutes “public performances, clinics, workshops, athletic and other competitions,
        and exhibitions” for generally authorized travel?
        

        OFAC has issued an expanded general license that incorporates prior specific licensing policy
        and authorizes, subject to conditions, travel-related transactions and other transactions that are
        directly incident to participation in amateur and semi-professional international sports federation
        competitions as well as other athletic and other competitions and public performances, clinics,
        workshops, and exhibitions in Cuba. For a complete description of what this general license
        authorizes and the restrictions that apply, please see 31 CFR § 515.567.
        

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

        OFAC has issued a general license that incorporates prior specific licensing policy and
        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. 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,
        please see 31 CFR § 515.574.
        

    18. What constitutes “humanitarian projects” for generally authorized travel and other
        transactions?
        

        OFAC has issued a general license that incorporates prior specific licensing policy and
        authorizes, subject to conditions, transactions, included travel-related transactions, that are related
        to humanitarian projects in or related to Cuba. These authorized humanitarian projects include
        medical and health-related projects; construction projects intended to benefit legitimately
        independent civil society groups; disaster relief; historic preservation; environmental projects;
        projects involving formal or non-formal educational training, within Cuba or off-island, on the
        following topics: entrepreneurship and business, civil education, journalism, advocacy and
        organizing, adult literacy, or vocational skills; community-based grassroots projects; projects
        suitable to the development of small-scale private enterprise; projects that are related to
        agricultural and rural development that promote independent activity; microfinancing projects,
        except for loans, extensions of credit, or other financing prohibited by 31 C.F.R. § 515.208; and
        projects to meet basic human needs. 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, please see 31
        CFR § 515.575.
        

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

        OFAC has issued a general license that incorporates previous specific licensing policy and
        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. 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,
        please see 31 CFR § 515.576.

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

            OFAC has issued a general license that incorporates prior specific licensing policy and
            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 in Cuba. 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, please see 31 CFR § 515.545. The
            definition of “information and informational materials” may be found at 31 CFR § 515.332.
            

        21. Can I purchase a ticket to Cuba directly from an airline based or operating out of the
            United States?
            

            Yes, provided that you are authorized to travel to Cuba pursuant to a general or specific license.
            Airlines subject to U.S. jurisdiction are authorized to provide air carrier services to authorized
            travelers, and travelers may purchase tickets provided that their travel is authorized pursuant to
            the CACR. Airlines and travelers are responsible for maintaining records of their Cuba-related
            transactions for at least five years.
            

        22. May a person that qualifies for the general license to provide carrier services transport a
            third-country national located in the United States to Cuba for travel authorized by a
            general license under one of the 12 categories of travel listed in Section 515.560 or by
            specific license from OFAC?
            

            Yes.
            

        23. May I take a commercial passenger ferry to travel to Cuba?
            

            Yes, provided that you are authorized to travel to Cuba pursuant to a general or specific license.
            Persons subject to U.S. jurisdiction are authorized to provide carrier services by vessel to
            authorized travelers, and travelers may purchase tickets provided that their travel is authorized
            pursuant to the CACR. The authorization to provide carrier services is limited to transportation
            of authorized travelers between the United States and Cuba and does not allow for stops in a third
            country. For a complete description of what this general license authorizes and the restrictions
            that apply, please see 31 CFR § 515.572.
            

        24. May an individual authorized traveler use his or her private boat to travel to Cuba?
            

            A person subject to U.S. jurisdiction engaging in authorized travel pursuant to an OFAC general
            or specific license may use a personal boat for his or her travel to Cuba provided that the
            temporary sojourn of the vessel is authorized by the Bureau of Industry and Security (BIS), and
            provided that he or she otherwise complies with all other applicable U.S. government laws and
            regulations. Goods exported to Cuba also require a license or must be eligible for a license exception from BIS. Please also see additional guidance on the OFAC website titled Guidance

            Regarding Travel Between the United States and Cuba.
            

            25. Are U.S. vessels, including private boats and commercial passenger ferries, permitted to
                

                carry passengers to or from Cuba?
                

                OFAC has issued a general license authorizing the provision of carrier services between the
                United States and Cuba by vessel, in addition to the existing authorization for provision of such
                services by aircraft. Those providing carrier services between the United States and Cuba may
                require additional authorizations from other U.S. government agencies. Goods exported to Cuba
                may also require separate authorization from BIS.
                

            26. May vessels transporting authorized travelers to Cuba provide lodging services?
                

                Yes. Section 515.572(a)(4) of the CACR permits persons subject to U.S. jurisdiction providing
                authorized carrier services by vessel to also provide lodging for authorized travelers onboard
                during the period of time the vessel is traveling to, from, or within Cuba, including when docked
                in a port in Cuba.
                

            27. Are authorized U.S. travelers permitted to travel onboard vessels in Cuba to meet their
                transportation needs within Cuba?
                

                Travel onboard a vessel in Cuba is permitted for authorized travel.
                

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

                There is no specific dollar limit on authorized expenses. 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. In addition, travelers are
                authorized to acquire in Cuba and import as accompanied baggage into the United States
                merchandise with a value not to exceed $400 per person, provided that no more than $100 of the
                merchandise consists of alcohol or tobacco products and the merchandise is imported for personal
                use only.
                

            29. Are there any restrictions on what foreign persons entering the United States from travel
                that included Cuba may bring in their accompanied baggage?
                

                A non-U.S. person (i.e. not a U.S. citizen or resident) arriving in the United States is authorized to
                import Cuban-origin merchandise, other than tobacco and alcohol, as accompanied baggage
                provided the merchandise is not in commercial quantities and not imported for resale. See 31
                CFR § 515.569. If the non-U.S. person is on a trip that included travel to Cuba, the person also is
                authorized to import as accompanied baggage alcohol or tobacco products purchased or otherwise
                acquired in Cuba with a value not to exceed $100 for personal use only. See 31 CFR
                

                § 515.560(c)(3).
                

            30. Can I purchase Cuban-origin cigars and/or Cuban-origin rum or other alcohol while
                traveling in Cuba?
                

                Persons authorized to travel to Cuba may purchase alcohol and tobacco products while in Cuba
                for personal consumption while there. Authorized travelers may return to the United States with up to $100 worth of alcohol and/or tobacco products acquired in Cuba in accompanied baggage,
                for personal use only.

                31. Can I purchase Cuban-origin cigars and/or Cuban-origin rum or other Cuban-origin
                    alcohol over the internet or while in a third country (i.e., not Cuba)?
                    

                    No. These transactions remain prohibited, and OFAC has not issued any general license that
                    would authorize them.
                    

                32. As an authorized traveler, may I travel from a third country to Cuba and from Cuba to a
                    third country?
                    

                    Yes, a person subject to U.S. jurisdiction engaging in authorized travel-related transactions may
                    travel to Cuba from a third country or to a third country from Cuba. Persons subject to U.S.
                    jurisdiction traveling to and from Cuba via a third country may only do so if their travel-related
                    transactions are authorized by a general or specific license issued by OFAC, and are subject to the
                    same restrictions and requirements as persons traveling directly from the United States.
                    

                III. Travel and Carrier Services
                

                33. Do air carriers or vessel operators need to obtain specific licenses from OFAC to provide
                    services?
                    

                    No. An expanded general license authorizes persons subject to U.S. jurisdiction to provide
                    carrier services by vessel or aircraft to, from, or within Cuba, in connection with authorized
                    travel, without the need for a specific license from OFAC. However, while no additional license
                    is required from OFAC, persons providing carrier services may still need to secure regulatory
                    approvals from other concerned U.S. government agencies, including the Department of
                    Commerce’s Bureau of Industry and Security, the Department of Transportation’s Office of the
                    Secretary and the Federal Aviation Administration, and the Department of Homeland Security.
                    For a complete description of what the OFAC general license authorizes and the restrictions that
                    apply, please see 31 CFR § 515.572.
                    

                34. 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, please see 31 CFR § 515.572(a)(1). The provision of
                    services related to travel for tourist or other unauthorized travel to Cuba remains prohibited.
                    

                35. Are airlines, vessel operators, and travel service providers required to verify that an
                    individual traveler is authorized to travel to Cuba?
                    

                    Persons subject to U.S. jurisdiction providing authorized carrier or travel services must retain for
                    at least five years from the date of the transaction a certification from each customer indicating
                    the provision of the CACR that authorizes the person to travel to Cuba. In the case of a customer
                    traveling under a specific license, a copy of the license must be maintained on file. The names
                    and addresses of individual travelers must also be maintained on file for at least five years. See
                    31 CFR § 515.572(b).

                    36. To which travelers may I provide carrier services between the United States and Cuba?
                    

                    Please see additional guidance on the OFAC website titled Guidance Regarding Travel between
                    the United States and Cuba.

IV. Remittances

37. What changes have been made with respect to authorized remittances by U.S. persons to
Cuba?

Effective September 21, 2015, the dollar limits on generally licensed donative remittances that
may be sent to a Cuban national, other than a prohibited official of the Government of Cuba or a
prohibited member of the Cuban Communist Party, have been removed. Additionally,
remittances of blocked funds to any Cuban national, other than a prohibited official of the
Government of Cuba or a prohibited member of the Cuban Communist Party, pursuant to a valid
testamentary disposition, intestate succession, or payment from a life insurance policy or annuity
contract triggered by the death of the policy or contract holder are now authorized by general
license.

Furthermore, OFAC has issued a new general license in 31 CFR § 515.570(h) authorizing the
unblocking and return of remittances that were previously blocked for exceeding the previous per
quarter limits on authorized periodic remittances to non-family members, provided that these
remittances would have been authorized under the current regulations. See further discussion on
the handling of blocked funds below.

Effective January 16, 2015, certain remittances to Cuban nationals for humanitarian projects,
support for the Cuban people, or development of private business are generally authorized.

Additional types of remittances are authorized by general license or may be authorized by
specific license. Please see 31 CFR § 515.570 for a complete description of what the OFAC
general licenses authorize and the restrictions that apply, as well as statements of specific
licensing policy.

The dollar limit on authorized remittances travelers to Cuba may carry has been removed. For a
complete description of this authorization and the restrictions that apply, please see 31 CFR
§ 515.560(c)(4) and (d)(2).

38. Is a bank, credit union, or money service business (MSB) such as a money remitter
permitted to process my authorized remittances to or from Cuba?

Yes. Pursuant to a general license, banking institutions, as defined in 31 CFR § 515.314, U.S.-
registered brokers or dealers in securities, and U.S.-registered money transmitters are permitted to
process authorized remittances to or from Cuba without having to obtain a specific license,
subject to the recordkeeping and reporting requirements set forth therein. For a complete
description of what the OFAC general license authorizes and the restrictions that apply, please
see 31 CFR § 515.572(a)(3).

V. Banking

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

    Under a new general license, 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 the OFAC general license authorizes and
    the restrictions that apply, please see 31 CFR § 515.560(c)(6).
    

40. Are authorized travelers in Cuba permitted to use credit or debit cards issued by a U.S.
    financial institution?
    

    Yes. Travelers are advised to check with their financial institution before traveling to Cuba to
    determine whether the institution has established the necessary mechanisms for its issued credit
    or debit cards to be used in Cuba. See 31 CFR § 515.560(c)(5) and 515.584(c).
    

41. Can my bank refuse to allow me to use my credit or debit card in Cuba?
    

    OFAC regulations do not require financial institutions or credit card companies to accept,
    maintain, or facilitate authorized financial relationships or transactions.
    

42. Can U.S. financial institutions permit the use of credit and debit cards they issue by, and
    process credit and debit card transactions for, third-country nationals whose travel to,
    from, or within Cuba may not fall within the 12 categories of authorized travel?
    

    Yes. Section 515.584(c) of the CACR authorizes all transactions incident to the processing and
    payment of credit and debit cards transactions for third-country nationals traveling to, from, or
    within Cuba.
    

43. Are financial institutions other than banks permitted to open correspondent accounts in
    Cuba?
    

    Depository institutions, as defined in 31 CFR § 515.333, which include certain financial
    institutions other than banks, are permitted to open correspondent accounts at banks in Cuba. See
    31 CFR § 515.584(a).
    

44. Are Cuban banks permitted to open correspondent accounts at U.S. banks?
    

    No. U.S. depository institutions are permitted to open correspondent accounts at Cuban banks
    located in Cuba and in third countries, and at foreign banks located in Cuba, but Cuban banks are
    not generally licensed to open such accounts at U.S. banks. See note to 31 CFR § 515.584(a).
    

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

    Depository 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 while the Cuban national is lawfully
    present in the United States.

In addition, OFAC is amending section 515.571 of the CACR to remove the $250 cap on
payments from blocked accounts held by Cuban nationals in the United States in a non-immigrant
status to use for living expenses or other transactions ordinarily incident to their presence in the
United States in a non-immigrant status or pursuant to another non-immigrant travel authorization
issued by the U.S. government. For a complete description of what the OFAC general license
authorizes and the restrictions that apply, please see 31 CFR § 515.571.

46. May U.S. banks, their foreign branches, and foreign subsidiaries open and operate accounts
    for Cuban nationals in third countries?
    

    OFAC has issued an expanded general license that authorizes all persons subject to U.S.
    jurisdiction to provide goods and services to Cuban national individuals located in a third
    country, provided that the transaction does not involve commercial exportation to or from Cuba.
    Additionally, the general license authorizes banking institutions to open, maintain, and close bank
    accounts for such Cuban nationals, provided that such accounts are used only while the Cuban
    national is located outside of Cuba and may not be used for transactions that involve a
    commercial exportation of goods or services to or from Cuba. For a complete description of what
    the OFAC general license authorizes and the restrictions that apply, please see 31 CFR § 515.585.
    

47. In what ways can Cuban nationals lawfully present in the United States participate in the
    U.S. financial system?
    

    Certain Cuban nationals who have taken up residence in the United States on a permanent basis
    and who meet the requirements set forth in 31 CFR § 515.505(a) are licensed as unblocked
    nationals, and may participate fully in the U.S. financial system. See 31 CFR § 515.505(a)(1) and
    (d).
    

    Pursuant to 31 CFR § 515.571, Cuban nationals who are present in the United States in a non-
    immigrant status or pursuant to other non-immigrant travel authorization issued by the U.S.
    government, such as a non-immigrant visa, may open and maintain bank accounts in the United
    States, provided that the Cuban-national account holder may only access the account while
    lawfully present in the United States. Section 515.571 also authorizes such Cuban nationals to
    engage in normal banking transactions involving foreign currency drafts, travelers’ checks, or
    other instruments negotiated incident to travel in the United States.
    

48. If a Cuban national resident in the United States has applied to become a lawful permanent
    resident alien of the United States, does that individual have to apply to OFAC to be treated
    as an unblocked national?
    

    No. If a Cuban national has taken up residence in the United States and has applied to become a
    lawful permanent resident alien of the U.S. and has an adjustment of status application pending,
    then the Cuban national is considered unblocked and does not need to apply to OFAC to be
    treated as an unblocked national, provided that he or she is not a prohibited official of the
    Government of Cuba or a prohibited member of the Cuban Communist party. See 31 CFR
    

    § 515.505(a)(1).
    

49. Should financial institutions apply for a specific license to unblock funds transfers or
    accounts which meet the conditions for unblocking set forth in 31 CFR §§ 515.505, or
    515.584 (e)?

The CACR include a general license authorizing banking institutions to unblock any account that
had been previously blocked solely because of the interest therein of one or more persons now
licensed as unblocked nationals. For a complete description of what this general license
authorizes and the restrictions that apply, please see 31 CFR § 515.505(b).

The CACR also include a general license at 31 CFR § 515.584(e) that unblocks funds transfers
that could have been processed or rejected pursuant to 31 CFR §§ 515.562(b), 515.579(b),
515.584(d)(1), or 515.584(d)(2) if the processing or rejection of those transfers would have been
authorized by the current text of the general licenses. Funds unblocked pursuant to 515.584(e)
must be reported to OFAC. For a complete description of what this general license authorizes
and the restrictions that apply, please see 31 CFR § 515.584.

If your situation appears to meet the requirements of these general licenses, OFAC suggests that
you contact the financial institution maintaining the blocked account or blocked funds transfer to
request that it review your situation within the context of the terms of the appropriate general
license. If the terms of a general license apply, there is no need to seek specific license
authorization from OFAC. It is OFAC’s policy not to grant specific licenses authorizing
transactions for which the provisions of an outstanding general license are applicable. See 31
C.F.R. § 501.801(a).

50. Do U.S. depository institutions need to apply for a specific license to release funds transfers
or accounts previously blocked pursuant to the CACR that are now authorized by general
license?

If a transaction was previously blocked pursuant to the CACR at the time of the transaction, and
the CACR was later amended to allow similar transactions, the earlier transaction is not
unblocked unless the CACR amendments include a general license that unblocks previously
blocked funds. Transactions must be authorized pursuant to the CACR at the time that they are
processed. To the extent that the unblocking of a funds transfer or blocked account is not
authorized by a general license, a specific license would be required to release funds transfers or
unblock accounts previously blocked.

51. What transactions involving wire transfers to Cuba are authorized?

OFAC has issued a general license that authorizes U.S. depository institutions to reject funds
transfers originating and terminating outside the United States where neither the originator nor
the beneficiary is a person subject to U.S. jurisdiction and provided that certain prohibited
individuals do not have an interest in the transfer. U.S. depository institutions are also authorized
to process such funds transfers where they would be authorized pursuant to the CACR if the
originator or beneficiary were a person subject to U.S. jurisdiction. For a complete description of
what this general license authorizes and the restrictions that apply, please see 31 CFR

§ 515.584(d).

52. 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 authorized. Such transactions may include use of online payment platforms to
facilitate authorized transactions. Please see the interpretive guidance in 31 CFR § 515.421.

53. 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 licensed by OFAC. An OFAC general license authorizes the exportation from the United
    States, and the reexportation of 100% U.S.-origin items from third countries, to Cuba only in
    those cases where the exportation or reexportation is licensed or otherwise authorized by the
    Commerce Department’s Bureau of Industry and Security (BIS). BIS currently authorizes limited
    categories of items to be exported or reexported to Cuba.
    

54. 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(d), 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 negotiation,
    accompanied delivery, or servicing in Cuba of items consistent with the export or reexport
    licensing policy of the Commerce Department,” or (2) 31 C.F.R. § 515.564(a), which authorizes
    transactions related to professional research or professional meetings in Cuba. For a complete
    description of what these general licenses authorize and the restrictions that apply, please see 31
    CFR §§ 515.533(d) and 515.564(a).
    

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

    Persons subject to U.S. jurisdiction in the following categories are authorized to 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: new 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. For a complete description of what this general license authorizes and the
    restrictions that apply, please see 31 CFR § 515.573.
    

56. Are insurers allowed to provide travel insurance for authorized travel to Cuba?
    

    Yes. See 31 CFR § 515.560.
    

57. 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 as global policy. 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, 31 CFR § 515.560, authorizes the provision of health,
    life, and travel insurance-related services for authorized U.S. travelers.
    

    58. May U.S. insurers, either directly or through third-country subsidiaries, issue policies, or
        pay insurance or reinsurance claims related to non-U.S. persons providing goods or services
        that facilitate travel by third-country nationals from a third country to Cuba?
        

        Other than certain global health, life, or travel insurance policies for individuals, absent specific
        authorization from OFAC, U.S. insurers and their subsidiaries are not permitted to issue policies,
        provide reinsurance coverage, or pay insurance or reinsurance claims related to non-U.S. persons,
        including entities such as foreign airlines, providing goods or services that facilitate travel by
        third-country nationals from a third country to Cuba.
        

    59. Are insurance policies that are issued to a “group” (e.g., an employer and its employees)
        authorized by the CACR?
        

        Section 515.580 of the CACR authorizes global insurance policies covering individuals ordinarily
        resident in a country outside of Cuba traveling to Cuba. The policy may be issued to a group,
        such as all employees of a company. The “global” requirement means it cannot be specific to
        travel to Cuba. For example, it does not authorize an individual travel policy issued to a traveler
        specifically to cover a planned trip to Cuba. It also does not authorize issuing a policy to a non-
        U.S. travel agent specifically to cover its traveler clients where the travel agency is solely in the
        business of planning trips to Cuba.
        

    60. What types of Cuban-origin goods are authorized for importation directly into the United
        States?
        

        Persons subject to U.S. jurisdiction authorized to travel to Cuba may import into the United States
        as accompanied baggage merchandise acquired in Cuba with a value not to exceed $400 per
        person, including no more than $100 in alcohol and tobacco products.
        

        Persons subject to U.S. jurisdiction are also authorized to import certain goods produced by
        independent Cuban entrepreneurs as determined by the State Department, as set forth in the State
        Department’s Section 515.582 list. For travelers importing authorized goods into the United
        States pursuant to § 515.582 as accompanied baggage, the $400 monetary limit does not apply to
        such goods. If these goods are for personal use, certain personal exemptions from U.S. Customs
        and Border Protection may apply.
        

        The importation into the United States from Cuba of information and informational materials is
        exempt from the prohibitions of the CACR. The definition of “information and informational
        materials” may be found at 31 CFR § 515.332.

VII. Telecommunications
61. What types of telecommunications services are recently authorized under general license?

Effective January 16, 2015, OFAC issued an expanded general license which, subject to
conditions, generally authorizes transactions that establish mechanisms to provide commercial
telecommunications services in Cuba or linking third countries and Cuba. OFAC has also updated the general licenses authorizing telecommunications-related transactions, including
payment related to the provision of telecommunications involving Cuba or provided to Cuban
individuals. Pursuant to this provision, U.S. persons may, for example, purchase calling cards for
people to use in Cuba and/or may pay the bills of such people directly to a telecommunications
operator located in Cuba, such as ETECSA. These steps to facilitate improved access to
telecommunications services for Cubans and increased international connections are intended to
increase the ability of the Cuban people to communicate freely and to better provide for efficient
and adequate telecommunications services between the United States and Cuba.

Persons subject to U.S. jurisdiction that are providers of telecommunications or internet-based
services who establish a physical presence in Cuba pursuant to the authorization in 31 CFR
§ 515.573 are authorized to engage in marketing related to that physical presence.

65. Are persons subject to U.S. jurisdiction engaging in authorized transactions permitted to
enter in arrangements with Cuban state-owned entities, such as ETECSA?

Individuals or entities subject to U.S. jurisdiction engaging in authorized transactions, either
pursuant to a general or specific license, may engage with Cuban state-owned entities as
authorized by the OFAC license. For example, a U.S. company engaging in authorized
telecommunications-related transactions pursuant to 31 C.F.R. § 515.542, such as payment for
activation, installation, usage, roaming, maintenance, or termination fees, may engage directly
with the Cuban state-owned telecommunications company, ETECSA, for these authorized
purposes.