OFAC FAQ (Current) # 1176 - Cuba Sanctions

Date issued: May. 28 2024

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TURBOFAC Commentary (167 words)

Notes:

1) This FAQ, which could be regarded as a sort of soft safe harbor for diligence purposes, follows the “may reasonably rely…unless…know or have reason to know” formulation found in other OFAC FAQs such as FAQ # 1106 and FAQ # 1044. This appears to be OFAC’s way of saying that due diligence expectations in this particular context would not entail seeking the corroboration of “information provided to [U.S. persons] by their customers in the ordinary course of business,” but if there is something in such information presenting a clear enough red flag to cast doubt on its legitimacy, there would be no space for “reasonable reliance”. See 515.578 and comments thereto for more on the GL referred to here. Compare FAQ # 1174 (issued on the same day).

* For comments on the scope of “communications”-related GLs in general, see section...