766. What types of payment or financing terms may be utilized for authorized exports and reexports of items other than agricultural commodities to Cuba?
Section 515.533(a) of the CACR does not restrict payment and financing terms for exports of items from the United States or reexports of 100 percent U.S-origin items from a third country, other than agricultural commodities. Examples of permissible payment and financing terms for authorized exports and reexports that are not agricultural commodities include: payment of cash in advance; sales on an open account; and financing by U.S. or third-country financial institutions.
OFAC has issued a general license authorizing banking institutions to provide financing for such authorized exports or reexports of items other than agricultural commodities, including issuing, advising, negotiating, paying, or confirming letters of credit (including letters of credit issued by a financial institution that is a national of Cuba), accepting collateral for issuing or confirming letters of credit, and processing documentary collections. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.584(f). With the exception of transactions related to exports or reexports of medicines or medical supplies, items associated with the provision of telecommunications and internet services for the Cuban people, or items associated with air and sea operations that support permissible travel, cargo, or trade, the general license at § 515.584(f) excludes direct or, effective September 30, 2026, indirect financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct and indirect financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209.
Date Updated: September 29, 2026
Updated on Sep 29, 2026
Cuba Sanctions
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766. What types of payment or financing terms may be utilized for authorized exports and reexports of items other than agricultural commodities to Cuba?
Section 515.533(a) of the CACR does not restrict payment and financing terms for exports of items from the United States or reexports of U.S-origin items from a third country, other than agricultural commodities. Examples of permissible payment and financing terms for authorized exports and reexports that are not agricultural commodities include: payment of cash in advance; sales on an open account; and financing by U.S. or third-country financial institutions.
OFAC has issued a general license authorizing banking institutions to provide financing for such authorized exports or reexports of items other than agricultural commodities, including issuing, advising, negotiating, paying, or confirming letters of credit (including letters of credit issued by a financial institution that is a national of Cuba), accepting collateral for issuing or confirming letters of credit, and processing documentary collections. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.584(f). In accordance with the NSPM, OFAC amended this general license to exclude from the authorization certain direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209. [09-06-2019]
[9-30-26 – FAQ amended to (i) re-instate “100 percent U.S-origin items” as the standard for coverage by 515.533(a) with respect to items exported from a third country, and (ii) reflect expansion of 560.209 to “indirect” financial transactions and associated amendments to GLs].
1) See 515.533, comments thereto, and Transcript; OFAC-BIS "Webinar – Sanctions Update Cuba/Iran/Russia" (2016), concerning the relaxation of the "100 percent U.S-origin items" standard. See also 515.584, and comments thereto, concerning financing for Ag exports restricted as a result of TSRA.
2) FAQ 766, when read in conjunction with the structure and notes to 515.533 of the CACR, appears to serve to clarify that, when "payment and financing terms" are NOT explicitly restricted, transactions "ordinarily incident to the [licensed] exportation of items" include, at a minimum, "payment of cash in advance; sales on an open account; and financing by U.S. or third-country financial institutions." With respect to "sales on an open account," contrast the guidance in FAQ with 560.532 of the ITSR. It appears the restriction on the transfer of receivables in connection with sales on open account is particular to 560.532 -- when sales on open account are otherwise implicitly authorized, as they are in 515.533, there is no reason to believe that the transfer of receivables is not also licensed.