OFAC FAQ (Current) FAQ # 756 - Cuba-related: Banking

Date issued: Sep. 30 2026

Last substantive commentary amendment:
Oct. 02 2026

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TURBOFAC Commentary (100 words)

Notes:

[9-30-26 Update – FAQ amended to reflect expansion of 560.209 to “indirect” financial transactions]

1) Given that this is an application of the typical "ordinarily incident" interpretive provision (515.421), rather than a general license specific to the CACR, this guidance should apply across programs. Payment processing is generally considered authorized as a transaction ordinarily incident to another authorized transaction, even when the authorization for the underlying transaction is silent on the question of payment processing. Here, there is no reason to believe that the use of online platforms is acceptable only for the purposes of the CACR. (Compare Earthquake Relief Efforts in Syria - Question # 6).

2) Note that OFAC is referring to the use of "online payment platforms to facilitate or process authorized transactions," by persons subject to U.S. jurisdiction. This does...