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OFAC’s CACR Changes FAQ, Part 3: Remittances

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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).


Filed under: Cuba Sanctions, Frequently Asked Questions (FAQ), Guidance, OFAC Updates

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