On 25 November 2015, OFAC issued Frequently Asked Question No. 52, answering a concern that US financial institutions had raised in connection with processing financial transactions related to travel by US persons to Cuba. Since January of this year, specific licenses from OFAC have generally not been required for travel to Cuba as long as the travel falls within one of twelve permitted categories specified in the Cuban Assets Control Regulations. The new FAQ clarifies that financial institutions may rely on travellers to self-certify their authorisation to travel directly to their travel service providers or carriers, unless the financial institution knows or has reason to know the travel is unauthorised.
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OFAC Clarifies Obligations of US Financial Institutions in Processing Transactions Related to Cuba Travel
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