OFAC Cuba Sanctions Screening

Screening under the comprehensive Cuba sanctions program, with limited exceptions for family remittances, humanitarian projects, and authorized travel.

TL;DR

TL;DR: Cuba is subject to comprehensive sanctions, meaning broad restrictions with narrow exceptions for remittances, humanitarian work, and licensed travel. Screening must confirm a counterparty and activity fall within an allowed category.

What comprehensive sanctions mean

A comprehensive program restricts transactions with a country as a whole, not just named parties. For Cuba, the restrictions are broad, and permissible activity sits inside specific exceptions such as family remittances, humanitarian projects, and authorized travel categories. A counterparty that appears clean on a name list can still be problematic if the transaction itself is prohibited.

Why it matters for agent payments

Jurisdictional restrictions mean screening needs a country dimension, not only a name check. The live data set spans 16 jurisdictions and syncs hourly, so a screening call can flag the country associated with a counterparty. An agent paying across borders should screen both the counterparty and the jurisdiction to avoid moving funds into a comprehensively sanctioned country.

What to verify

• Counterparty identity against the SDN List
• Jurisdiction of the counterparty and transaction
• Whether an exception or license applies

Why jurisdiction matters more than names

For comprehensive programs, jurisdiction matters more than the counterparty's name. A person or entity in Cuba may never appear on the SDN List, yet a transaction with them is still restricted. That is why screening must combine the list check with a jurisdiction check, and why the country of the counterparty is part of the risk signal. An agent that screens only names will miss the jurisdictional prohibition entirely.