The old payment route has closed: Cuba’s September 30 sanctions changes
OFAC removed U-turn payment permission, widened Cuba Restricted List controls and changed travel authorizations. Part 516 adds a separate layer.
Sanctions · 02 Oct 2026
A Cuba-related payment that began and ended outside the United States could previously pass through a U.S. bank under the CACR’s U-turn authorization, if its conditions were satisfied. That route changed on September 30, 2026. A travel file can have the same problem: the authorization recorded when the trip was planned may no longer authorize the next transaction. For your company, the immediate task is to identify the permission on which the payment or trip actually depends.
What happened
OFAC issued two separate final rules effective September 30. One amended the Cuban Assets Control Regulations, or CACR, in 31 C.F.R. part 515. The other introduced the Cuba Sanctions Regulations in part 516 to implement Executive Order 14404. The second rule is not a replacement for the first. A Cuba-related transaction may need to satisfy both sets of applicable requirements.
Our July article on Executive Order 14404 described the order’s carve-out for activities authorized by CACR licenses. That carve-out does not freeze those licenses against later amendment. The September 30 CACR rule changed what certain authorizations cover.
Payments: trace the originator and ultimate beneficiary
Amended § 515.209 reaches direct and indirect financial transactions with entities and subentities named on the State Department’s Cuba Restricted List, unless otherwise authorized or within the section’s exceptions. A direct financial transaction involves acting as originator or ultimate beneficiary. An indirect one involves participating in a funds transfer without occupying either role, where the originator or ultimate beneficiary is a listed entity or subentity. The definitions apply to the CACR; they should not be imported wholesale into another sanctions program. A companion amendment to § 515.201(c) prohibits transactions that have the purpose or effect of evading the § 515.209 prohibition.
Section 515.209(b) and (c) carve out travel-related transactions initiated, and commercial engagements in place, before the relevant entity was added to the Restricted List as published in the Federal Register. Those conditions require evidence of the engagement and the entity’s listing date. A general statement that the relationship is longstanding does not establish them. Nor does the Restricted List automatically include every subsidiary of a listed entity: its note requires the entity or subentity itself to be named. Other sanctions rules may separately restrict it.
Section 515.584(d) no longer authorizes processing of the former U-turn transfers. It now authorizes U.S.-jurisdiction banking institutions to reject transfers that originate and terminate outside the United States, where neither originator nor beneficiary is subject to U.S. jurisdiction. The related unblocking-and-return authorization in § 515.584(e) no longer reaches transfers that would have qualified under the former U-turn license. Funds already blocked on that basis may therefore need another authorization or a specific license before release.
OFAC also removed the authorization for U.S.-jurisdiction banks to open and maintain certain accounts solely in the name of Cuban independent private-sector entrepreneurs. The rule explains that a specific license is required to unblock funds in those accounts.
Travel: cancellation and grandfathering have different conditions
The professional-meetings general license was removed. Its replacement allows limited wind-down for qualifying travelers already in Cuba on September 30, provided they depart by October 30, 2026. It also permits transactions ordinarily incident and necessary to terminating and obtaining refunds for qualifying trips until October 30. This is not an authorization to begin a new conference trip; OFAC now considers professional meetings outside other travel authorizations by specific license, case by case. Professional research remains separately authorized when its conditions are met; being a professional does not itself make a trip professional research.
Group people-to-people educational travel permission was also removed. Section 515.565(b) replaces it with a limited grandfathering route for a trip consistent with the former provision, where the traveler completed at least one travel-related transaction for that particular trip before September 30. Paragraph (c) contains a separate grandfathering provision for certain educational travel. New educational travel must fit the amended conditions, including applicable institutional sponsorship and accompaniment requirements. Restricted List and prohibited-accommodation exclusions still need attention.
Part 516 is a separate sanctions analysis
The new part 516 implements Executive Order 14404 in abbreviated form. It covers blocking and other sanctions imposed under that order, while preserving the separate operation of other sanctions provisions. Two texts need to be read together. The order states that its blocking and foreign-financial-institution provisions do not apply to activities authorized by a CACR license. Section 516.101 separately states that licenses under other parts do not authorize transactions prohibited by part 516. Do not assume a CACR permission answers every part 516 question; read the actual authorization and the property or person it covers.
For a non-U.S. bank, the order’s foreign-financial-institution authority requires a separate analysis. Treasury may impose the specified correspondent or payable-through account restrictions, or blocking, upon the required determination concerning significant transactions for or on behalf of persons blocked under the order. It is not an automatic sanction on every bank touching a Cuban payment.
What this means for you
Start with the pending payment and travel files. Record the parties, originator, ultimate beneficiary, banks, existing authorization and date of the next transaction. For a booked trip, preserve the booking evidence and identify the exact grandfathering or wind-down provision instead of assuming every earlier booking survives.
Then distinguish three decisions: whether the activity is authorized, how a bank must handle the payment, and whether another sanctions authority applies. These are practical review steps, not a promise that rerouting will make the transaction lawful. Contact Zimmermann Law to discuss your company’s U.S. sanctions analysis.
This post provides general information, not legal advice. Sanctions analysis is fact-specific and changes over time.
Sources: Cuban Assets Control Regulations amendments, 91 Fed. Reg. 61741–48 (Sept. 30, 2026), FR Doc. 2026-19973, §§ 515.201(c), 515.209, 515.564, 515.565 and 515.584; Cuba Sanctions Regulations, 31 C.F.R. part 516, 91 Fed. Reg. 61748–58 (Sept. 30, 2026), FR Doc. 2026-19977, §§ 516.101, 516.201 and 516.501, and appendix A (E.O. 14404 §§ 2(b), 4). Mandatory U.S. federal authority within its scope. Operative provisions and September 30/October 30 dates checked October 2, 2026.
This post is for general information and is not legal advice.
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