OFAC Strengthens Cuba Sanctions, Restricting Remittances and U-Turn Transactions

OFAC Strengthens Cuba Sanctions, Restricting Remittances and U-Turn Transactions


By: Michael T. Gershberg, Justin A. Schenck, Avani Uppalapati

On September 9, 2019, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to remove certain authorizations for remittances to Cuba and for banking institutions to process “U-turn” transactions in which the sender and recipient are outside U.S. jurisdiction.  The rule will be effective on October 9, 2019.  This amendment is another step in implementing President Trump's policy of restricting the Cuban government's access to funding, as outlined in the 2017 National Security Presidential Memorandum.
 

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