OFAC Cuban Assets Control Regulations amendment — indirect-transaction ban on Cuba Restricted List entities, U-Turn licence and group travel authorizations removed (NSPM-5)

Mechanism

Amended § 515.209 bars persons subject to US jurisdiction from participating, without being originator or ultimate beneficiary, in funds transfers where either end is a Cuba Restricted List entity; § 515.201(c) adds an evasion prohibition. Subpart E general licences that excluded direct dealings with listed entities now also exclude indirect ones. Removing the § 515.584(d) "U-Turn" licence ends US-bank processing of Cuba-interest transfers that originate and terminate offshore, so correspondent-bank exposure to Cuba rises.

Downstream implications

• Banks and payment processors must screen the Cuba Restricted List on intermediary legs, not only originator/beneficiary.
• Travel operators lose group people-to-people and professional-meeting general licences; specific licences remain case-by-case.

Open questions

• Content and growth of the Cuba Restricted List under NSPM-5's expanded listing criteria.