OFAC’s CACR changes FAQ, part 7: Third Party Effects

VIII. Third-Country Effects

66. Are Cuban nationals located outside of Cuba still considered blocked?
    

    Yes, but any individual Cuban national who can establish that he or she has taken up permanent
    residence outside of Cuba and otherwise meets the requirements set forth in 31 CFR § 515.505 is
    generally licensed as an unblocked national. Additionally all persons subject to U.S. jurisdiction
    are authorized to provide goods and services to Cuban national individuals located outside of
    Cuba, provided there is no commercial exportation of goods or services to or from Cuba. For a
    complete description of what this general license authorizes and the restrictions that apply, please
    see 31 CFR § 515.585.
    

67. Can U.S.-owned or -controlled entities in third countries engage in trade/commerce with
    Cuban nationals located outside of Cuba?
    

    U.S.-owned or -controlled entities in third countries may provide goods and services to a Cuban
    national located outside of Cuba, provided that the transaction does not involve a commercial
    exportation, directly or indirectly, of goods or services to or from Cuba. For a complete
    description of what this general license authorizes and the restrictions that apply, please see 31
    CFR § 515.585.
    

68. Are U.S.-owned or -controlled entities in third countries authorized to provide financial
    services to Cuban nationals located outside of Cuba?
    

    Yes. U.S.-owned or -controlled entities in third countries may provide financial services to a
    Cuban national located outside of Cuba, provided that the transaction does not involve a
    commercial exportation, directly or indirectly, of goods or services to or from Cuba. For a
    complete description of what this general license authorizes and the restrictions that apply, please
    see 31 CFR § 515.585.