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ARTICLE · 11 SEPTEMBER 2019

OFAC Strengthens Cuba Sanctions Rules

Hogan Lovells Cadwalader
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OFAC amended the Cuban Assets Control Regulations ("CACR") to (i) revise authorizations concerning remittance allowances and (ii) eliminate

United StatesInternational Law

OFAC amended the Cuban Assets Control Regulations ("CACR") to (i) revise authorizations concerning remittance allowances and (ii) eliminate authorizations for so-called "U-turn" transactions.

The new amendments place restrictions on family remittances, eliminate "donative" remittances and add provisions authorizing certain remittances for independent non-governmental organizations and certain individuals in Cuba.

OFAC is amending the applicable general license, located at 31 CFR § 515.584(d), to eliminate the "U-turn" authorization (i.e., authorizations on transactions processed by a financial institution subject to U.S. jurisdiction, but that originate and terminate outside of the United States, and where neither the originator nor the beneficiary is a person subject to U.S. jurisdiction). Financial institutions subject to U.S. jurisdiction will be authorized to reject - but will not be required to block - such transactions.

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