OFAC bans indirect financial dealings with Cuba Restricted List entities

The Treasury Department's Office of Foreign Assets Control issued a final rule, FR Doc No 2026-19973, amending 31 CFR part 515. Effective September 30 2026, the rule adds a prohibition on indirect financial transactions with any entity or subentity on the Cuba Restricted List. The list's scope is expanded to include entities or subentities under the control of, or acting for, the Cuban military, intelligence, or security services.

Section 515.201(c) now contains a prohibition on any transaction whose purpose or effect is to evade the direct or indirect transaction bans. General licenses in subpart E are revised to exclude indirect transactions with restricted entities, and Sec. 515.421 clarifies that licensed transactions do not cover such financial dealings unless a license expressly permits them.

Financial-transaction authorizations are narrowed. The "U-Turn" general license at Sec. 515.584(d) and the related unblocking authority at Sec. 515.584(e) are removed and replaced with a requirement that banking institutions reject those transfers. Sec. 515.584(g) is amended to exclude indirect transactions with restricted entities from the authorization to process U.S.-dollar instruments presented indirectly by Cuban financial institutions. The authorization at Sec. 515.584(h)(2) allowing banks to open and maintain accounts solely in the name of Cuban private-sector entrepreneurs is eliminated; such accounts now require a specific OFAC license to unblock funds.

Travel and related authorizations are also tightened. Sec. 515.565(a) is revised to limit educational travel to accredited U.S. undergraduate or graduate-degree-granting institutions and to require that all other educational exchanges be sponsored by a U.S. organization and accompanied by a representative of that sponsor. Authorizations for group people-to-people travel and professional meetings in Cuba are removed.

The amendments implement provisions of National Security Presidential Memorandum-5 (2025 NSPM-5), signed by the President on June 30 2025, and bind all persons subject to U.S. jurisdiction, including banking institutions, U.S. persons, and entities operating under U.S. jurisdiction.