Archived Cuba FAQs - # 6

Date issued: Sep. 06 2019

TURBOFAC Commentary (130 words)

Notes:

1) FAQ archived in Sept. 2019 in light of the removal of the U-turn GL for Cuba.

2) Concerning the following statement:

"Further, the use of U.S. dollars for transactions that are exempt from the prohibitions of or not otherwise prohibited by the CACR is also authorized. For example, payments related to the importation or exportation of informational materials as defined in 31 CFR § 515.332, such as books or musical recordings, may be made in U.S. dollars."

The wording of those sentences is a bit loose. Technically, payments related to exempt transactions are themselves exempt; not "authorized." This distinction is frequently meaningful.

3) The FAQ illustrates examples of transactions that OFAC would consider "U-turn" transactions eligible for rejection, rather than blocking, under 515.584.