OFAC FAQ (Current) # 1256 - Cuba Sanctions

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (137 words)

Notes:

1) This FAQ is typical of FAQs addressing EOs that contain “operating in” designation criteria, where OFAC clarifies that persons are only blocked for “operating in” specified sectors when there are affirmative determinations to that effect. In some cases, “operating in” designation criteria are not used as quasi secondary sanctions authorities, i.e. they are used exclusively to target entities within the country that is the sanctions target. That does not appear to be OFAC’s intent with 14404, where it is warning that “foreign persons that operate or have operated in such sectors [are exposed] to sanctions risk” (see also U.S. Sanctions Target Cuba’s Military Regime, Elites (Press Statement)), but as of 5-11-26, only three Cuban Nationals have been blocked pursuant to the EO (see U.S. Sanctions Target Cuba’s Military Regime, Elites (Press Statement)).

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OFAC FAQ (Current) # 1256 - Cuba Sanctions

TURBOFAC Commentary (137 words)