On Wednesday, OFAC published an updated version of its Cuban sanctions Frequently Asked Question (FAQ) document. The new question (#52) is about banks' processing of authorized travel transactions vis a vis the Cuban sanctions program:
52. Is a financial institution required to independently verify that an individual’s travel is
authorized when processing Cuba travel-related transactions?No. A financial institution may rely on U.S. travelers to provide their certifications of authorized
travel directly to the person providing travel or carrier services when processing Cuba travel-
related transactions, unless the financial institution knows or has reason to know that the travel is
not authorized by a general or specific license.The CACR requires persons subject to U.S. jurisdiction providing travel or carrier services to
retain for at least five years from the date of the transaction a certification from each customer
indicating the section of the CACR that authorizes the person to travel to Cuba. See §
515.572(b). U.S. travelers utilizing a general or specific license are also required to retain for five
years records associated with their travel to Cuba.
So, since 52 is not the last question in the document, one has to assume that all the other higher-numbered questions got renumbered.
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Posted with BlogsyFiled under: Cuba Sanctions, Frequently Asked Questions (FAQ), OFAC Updates, Sanctions Regulations
