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Frequently Asked Questions

785. What types of internet-based services are authorized under general license?

Persons subject to U.S. jurisdiction may provide certain services incident to internet-based communications and related to certain authorized exportations and reexportations of communications items. For example, transactions incident to providing fee-based… Read more

786. Is “peering” — an arrangement of traffic exchange between internet networks — authorized by the CACR?

Yes. For example, a U.S. company could enter into a peering arrangement with ETECSA, the Cuban telecommunications provider, for the provision of internet services. See § 515.542(b).

787. Are services related to caching, such as the provision of data storage systems that reduce internet network traffic, authorized by the CACR?

Yes. Section 515.578 authorizes the exportation or reexportation to Cuba of services incident to the exchange of communications over the internet. To the extent data caching services are incident to such exchanges of communications, the provision of such… Read more

788. What type(s) of business arrangements are telecommunications and internet-based service providers that are subject to U.S. jurisdiction authorized to establish in Cuba?

Section 515.573 of the CACR contains a general license that authorizes certain persons subject to U.S. jurisdiction, including telecommunications and internet-based service providers, to establish a physical and business presence in Cuba to provide authorized… Read more

789. May persons subject to U.S. jurisdiction who open an authorized business or physical presence, such as a joint venture, office, or retail outlet, in Cuba market their telecommunications or internet-based services?

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

790. Are persons subject to U.S. jurisdiction engaging in authorized transactions permitted to enter into 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… Read more

791. Are Cuban nationals located outside of Cuba still considered blocked?

Yes, but any individual Cuban national who can establish that he or she has taken up permanent residence outside of Cuba and otherwise meets the requirements set forth in 31 CFR § 515.505 is generally licensed as an unblocked national. Additionally all… Read more

792. Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with Cuban nationals located outside of Cuba?

U.S.-owned or -controlled entities in third countries may provide goods and services to a Cuban national located outside of Cuba, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to or from… Read more

793. Are persons subject to U.S. jurisdiction authorized to provide financial services to Cuban nationals located outside of Cuba?

Yes. Persons subject to U.S. jurisdiction may provide financial services to a Cuban national located outside of Cuba who is an individual, provided that the transaction does not involve a commercial exportation, directly or indirectly, of goods or services to… Read more

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… Read more

795. Can a grant authorized pursuant to the CACR be awarded to a Cuban state-owned entity?

Section 515.590 of the CACR authorizes the provision of grants, scholarships, or awards to a Cuban national, including a Cuban state-owned entity provided that entity is not included on the State Department’s Cuba Restricted List, and as long as any such… Read more

796. Are specific licenses still required for transactions relative to the administration of a Cuban estate?

Section 515.523 of the Cuban Assets Control Regulations authorizes all transactions incident to the administration and distribution of the assets of a blocked estate of a decedent. All property distributed pursuant to 31 CFR § 515.523 is unblocked, provided… Read more

797. What types of projects would fall within the authorization in 31 CFR §515.575 for microfinancing projects?

Among other things, the provision for microfinancing projects in section 515.575 of the Cuban Assets Control Regulations (CACR) authorizes the provision of certain financial services to unemployed, underemployed, and low-income Cubans who have little or no… Read more

798. If a person had applied for a specific license from OFAC before the CACR was revised but now believes that the proposed activity is authorized pursuant to a general license, does that person need to wait for his or her specific license application to be adjudicated?

No. If persons meet the qualifications listed in the general license, then they do not need to wait for an official determination from OFAC regarding their specific license application. Persons who have determined they may proceed under a general license may… Read more

799. Is a person subject to U.S. jurisdiction allowed to purchase or lease real property in Cuba?

Generally no, a person subject to U.S. jurisdiction is not authorized to purchase or lease real property in Cuba. The CACR prohibit any person subject to U.S. jurisdiction from purchasing or leasing property in Cuba unless authorized by OFAC. Section 515.573… Read more

800. May persons subject to U.S. jurisdiction import Cuban-origin pharmaceuticals into the United States?

Section 515.547(b) of the CACR authorizes all transactions incident to obtaining approval from the U.S. Food and Drug Administration (FDA) of Cuban-origin pharmaceuticals. The general license includes discovery and development, pre-clinical research, clinical… Read more

801. May persons subject to U.S. jurisdiction provide services to Cuba or the Cuban government to support infrastructure maintenance and development in Cuba?

Section 515.591 of the CACR authorizes persons subject to U.S. jurisdiction to provide Cuba or Cuban nationals (including the Cuban government and state-owned entities) with services related to developing, repairing, maintaining, and enhancing Cuban… Read more

802. May persons subject to U.S. jurisdiction provide mail or parcel delivery services to Cuba or Cuban nationals?

With respect to the receipt or transmission of mail and parcels between the United States and Cuba, Section 515.542(a) of the CACR authorizes persons subject to U.S. jurisdiction to engage in all transactions, including payments, incident to such activities,… Read more

803. What types of activity does General License 35 authorize?

U.S. persons are authorized to engage in certain administrative transactions with the Government of Venezuela that are prohibited by E.O. 13884 of August 5, 2019, where such transactions are necessary and ordinarily incident to such persons’ day-to-day… Read more

804. Do sanctions on COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to its corporate parent and affiliates?

COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. was determined by the Secretary of State on September 25, 2019, to meet the criteria for the imposition of sanctions under Executive Order (E.O.) 13846, and the Secretary of State imposed certain… Read more