OFAC Tightens Cuba Sanctions: New Restrictions on Indirect Transactions
OFAC has amended the Cuban Assets Control Regulations to implement updated U.S. Cuba policy, adding a prohibition on indirect financial transactions with entities on the Cuba Restricted List and removing previously available authorizations, including 'U-Turn' transactions and certain travel-related licenses. Compliance officers must ensure their transaction monitoring and screening programs now catch indirect exposure to Cuba Restricted List entities, not just direct dealings. Payment processors, banks, and crypto firms routing or facilitating transactions with any Cuban nexus need to reassess their sanctions controls immediately.
What to do
- Review and update your Cuba sanctions screening procedures and transaction monitoring rules to prohibit indirect financial transactions with Cuba Restricted List entities and remove any reliance on now-revoked authorizations such as U-Turn transactions.
Who this affects
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Source
Read the official publicationThis radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.