§515.524 Payment from, and transactions in the administration of certain trusts and estates.
(a) Any bank or trust company incorporated under the laws of the United States, or of any State, territory, possession, or district of the United States, or any private bank subject to supervision and examination under the banking laws of any State of the United States, acting as trustee of a trust created by gift, donation, or bequest and administered in the United States, in which one or more persons who are designated nationals have an interest, beneficial or otherwise, or are co-trustees, is hereby authorized to engage in the following transactions:
(1) Payments of distributive shares of principal or income to all persons legally entitled thereto.
(2) Other transactions arising in the administration of such trust which might be engaged in if no Cuban national were a beneficiary or co-trustee of such trust.
(b)...
The relationship between this provision and the provisions pertaining to the administration of decedents' estates, and in particular 515.570(f)(1), is not entirely clear from the face of the regulations.
First, note that while provision does not specifically refer to payments made out of blocked accounts, the fact that the provision deals with trusts in which a designated national has an interest necessarily implies that they are blocked in principle. From 1963 through 2015, subsection (b) of this section stated "Any payment or distribution of any funds, securities or other choses in action to a national of a designated foreign country under this section shall be made by deposit in a blocked account in a domestic bank in the name of the national who is the ultimate beneficiary thereof."[1] In 2015, OFAC announced, without further specifics, that it was "substantially revising section...