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The OFAC Book of Why: Cuba sanctions (Part 4)

Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012.

Now, for the last set of sanctions details…

First, transactions related to “snail mail” between the US and Cuba? All OK.

Secondly, telecomunications:

  • US service providers can engage in transactions related to telecommunications, satellite radio and television, and roaming services with Cuban service providers.
  • US persons can contract and pay for the provision of telecomm services by non-Cuban service providers to non-prohibited Cuban individuals.
  • Transactions for establishing telecomm facilities for communications between the US and Cuba are authorized. You need a license for facilities linking Cuba and other countries, though.

If you do any of these, you have to notify OFAC within 30 days of starting or stopping offering these services. You also have to report twice a year on all the payments you have made relative to these services.

Next, exporting services related to Internet personal communications are generally authorized – these include instant messaging, chat & email, social networking, multimedia sharing, Web browsing, and blogging. OFAC may issue specific licenses for other similar services.

Additionally, authorized Travel, Carrier and Remittance Forwarding providers may not participate in discriminatory practices of the Cuban Government. In particular, permitting the tying of additional services to travel (i.e. requiring the purchase of additional services in order to travel to/from Cuba) is not permitted.

Also, estates and life insurance policy proceeds are property like any other – if a Cuban national has an estate or life insurance policy or has an interest in one, it is blocked.

Lastly, OFAC may issue specific licenses to pay Cuba for services relating to overflights or emergency landings by US planes.

Whew! And those are the Cuban sanctions regulations, as of the date of the flyer, in a very large nutshell…

Categories: Cuba Sanctions


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