Cuba Sanctions Lawyers – OFAC Compliance & Licenses

Effective navigation in the sanctions field requires precise separation of administrative and legal tasks. We have structured our support in such a way as to address specific requests — from launching an investment project to the urgent withdrawal of funds from under blocking.

The legal framework of the USA provides mechanisms for lawful interaction with Cuban counterparties; however, their use requires meticulous preparation of documents. Independent submission of an application without considering the current policy of the agency often leads to months-long delays or unmotivated refusals. Our assistance includes the following areas:

Blocking a dollar transfer through a correspondent bank in the USA paralyzes business processes and jeopardizes obligations to partners. In 2026, the procedure for releasing assets requires not only legal justification but also active interaction with the internal control services of financial organizations. Our experts take on:

Receiving an Administrative Subpoena or a Request for Information (RFI) from a regulator shifts the situation into the realm of potential criminal or civil liability. In such cases, a defense strategy must be developed immediately to prevent catastrophic penalties. We provide defense on the following points:

A deep understanding of the specifics of various markets allows us to adapt compliance strategies to the unique operational cycles of each industry. We have accumulated significant experience working in sectors most affected by Cuban sanctions:

The Cuban Assets Control Regulations (CACR) are a set of rules developed by the Office of Foreign Assets Control and outlined in the Federal Register to regulate economic relations between the United States and Cuba. They aim to pressure the Cuban government by limiting its access to U.S. financial and commercial resources.

The main aspects of the Cuban Assets Control Regulations (CACR) rules include:

Violating Cuba sanctions as outlined by the Treasury Department’s Office of Foreign Assets Control (OFAC) can lead to significant financial and legal consequences.

For example, a foreign company was fined millions for conducting financial transactions through American banks, which violated sanctions rules. This incident highlights the seriousness of OFAC’s control, which covers not only American organizations but also international entities dealing with dollar transactions.

Failing to comply with sanction restrictions can lead to significant reputational risks and financial losses for any company.

The Cuba sanctions by the Office of Foreign Assets Control entail severe financial penalties for both legal entities and individuals. In cases of violation sanctions programs possible imposition of administrative and criminal fines. Administrative penalties can reach up to $250,000 or twice the value of the prohibited transaction. Criminal penalties are even more severe – fines of up to $1 million and imprisonment for up to 20 years.

Civil liability includes freezing of assets belonging to individuals or organizations that violate sanctions. This means the State Department can block access to financial resources indefinitely. Additionally, individuals or companies affected by such violations have the right to file civil lawsuits, which can lead to further financial losses for the violators.

Thanks to a combination of financial penalties, asset freezes, and the possibility of legal action, these measures significantly complicate any attempts to circumvent established restrictions.

For travel to Cuba under the OFAC sanctions regime, two types of licenses are provided: general and specific.

A general license allows for travel without the need to submit a separate application to the Treasury Department’s Office of Foreign Assets Control, but only for specific categories, such as educational programs, humanitarian missions, or family visits. These trips must meet specific criteria clearly outlined in the United States and Cuba sanctions regulations.

An individual license requires prior authorization from the Office of Foreign Assets Control for travel that does not fall under the conditions of a general license. In such cases, a justification for the visit must be provided, which must comply with sanction exceptions.

This approach ensures strict control over travel, preventing unauthorized movements of individuals between the US and Cuba.

A general license is permission automatically granted by the Treasury Department’s Office of Foreign Assets Control for conducting certain types of activities, usually prohibited by Cuban sanctions. This type of license does not require submitting to an individual application or obtaining special permission, but it does require strict compliance with established conditions.

Even with a general license in place, some actions may require additional confirmation from OFAC or meticulous documentation of the transactions carried out. This is necessary to ensure that activities comply with established rules and to avoid potential sanctions.

General licenses apply to 12 categories of activities:

Adhering to the terms of the general license is mandatory for legally conducting activities within these categories. Violating established rules can lead to serious legal consequences.

A specific license is permission issued by OFAC for conducting a particular activity that is normally prohibited by sanctions against Cuba. It differs from a general license in that it requires the submission of an individual application and obtaining permission for a specific operation or project.

How are special licenses issued?

To obtain a specific license, an application must be submitted to OFAC. The application must clearly describe:

The decision to issue a license is made based on an analysis of the submitted documents, as well as the compliance of the proposed activity with the interests of U.S. policy towards Cuba.

What types of activities require a specific license?

Specific licenses are required in cases where the activity does not fall under general licenses. For example:

A specific license is a flexible tool that allows for operations within the strict confines of sanctions, but only if all OFAC requirements are meticulously adhered to.

Money transfers to Cuba are strictly regulated. Any transfers to Cuban government entities, state institutions, enterprises, or individuals listed on OFAC sanctions lists are prohibited.

Permitted Imports and Exports

Imports of Cuban agricultural products and artisan goods, such as souvenirs, are allowed in small quantities for personal use. Exports from the U.S. are possible for humanitarian aid, medical equipment, medications, and telecommunications devices provided they comply with OFAC licenses.

Restricted Goods and Trade Compliance

The import and export of most goods, such as industrial equipment, building materials, and electronics, are prohibited without a special license. Deals with Cuban state entities or companies associated with the government are completely forbidden. All operations must comply with OFAC sanctions requirements. Violations of the rules are punishable by fines or criminal liability.

The OFAC legal team will provide expert assistance in resolving issues related to Cuban sanctions. Contact us to receive professional support and effectively resolve your issues. We will help you navigate through regulatory documents, prepare the necessary paperwork for licenses, and ensure your activities comply with OFAC requirements. Reach out for expert consultation to avoid risks and penalties.