OFAC FAQ (Current) # 12756- Cuba Sanctions

Date issued: Oct. 15 2026

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TURBOFAC Commentary (94 words)

Notes:

1) Compare FAQ # 1254. This FAQ provides meaningful guidance concerning OFAC’s non-intent to consider “wind down” activities sanctionable even where such activities would not qualify for Cuba General License 1 if engaged in by a U.S. person. Query whether requests to OFAC for secondary sanctions comfort might more easily be addressed as “non-targeting postures” rather than guidance confirming that a given transaction does or does not qualify as a “significant transaction”. In the latter case, OFAC makes a legal determination that is arguably less meaningful than one-off “non-targeting postures”.