On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued new Frequently Asked Question (“FAQ”) 1190 to provide basic information on OFAC and sanctions. OFAC also amended FAQ 736 and FAQ 757 related to the Cuban Assets Control Regulations (“CACR”).
FAQ 1190 states that U.S. sanctions do not target persons for engaging in constitutionally protected activities, including political speech or religious practices. OFAC also updated FAQ 736 to clarify when the U.S. dollar can be used to conduct transactions in Cuba or with Cuban nationals. FAQ 757 was also updated to confirm that, as of May 29, 2024, U.S .banking institutions are authorized to process “U-turn” transactions in which Cuba or a Cuban national has an interest. According to OFAC, U-turn transactions are those in which the fund transfers originate and terminate outside the United States and neither the originator nor the beneficiary is a person subject to U.S. jurisdiction.