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FAQ 1271
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FAQ 1271

OFAC guidance applying Cuba's indirect-dealing ban to 18 general licences.

Released on 29 September 2026, FAQ 1271 explains how OFAC's ban on indirect dealings with Cuba Restricted List entities affects 18 general licences.

Last refreshed: 22 October 2026

Key Question

How widely does FAQ 1271 extend Cuba's indirect-transaction bar?

Timeline for FAQ 1271

#15 30 Sept

Applied the indirect bar to 18 general licences

Cuba Dispatch: OFAC closes Cuban firms' US accounts
View full timeline →

Background

FAQ 1271 is guidance from the US Treasury's Office of Foreign Assets Control on the Cuban Assets Control Regulations. It explains section 515.209, which bars indirect as well as direct financial transactions involving entities on the Cuba Restricted List. The guidance accompanied a regulatory amendment that took effect on 30 September 2026.

The FAQ identifies 18 general licences whose permissions do not extend to prohibited indirect transactions. Those licences include areas such as family visits and support for the Cuban people, so users must still check whether a payment reaches a restricted entity through an intermediary. FAQ 1271 interprets the regulation; it is not a separate statute or licence. Its practical role is to show that an otherwise authorised activity can still fail when its payment route involves a listed Cuban entity.

Common Questions
What is OFAC FAQ 1271?
It is OFAC guidance explaining how the September 2026 Cuba rules restrict indirect financial transactions involving Cuba Restricted List entities.Source: OFAC, US Treasury
Which general licences does FAQ 1271 cover?
It lists 18 general licences, including those for family visits, educational activities, religious activities and support for the Cuban people.Source: OFAC, US Treasury
When did OFAC FAQ 1271 take effect?
OFAC released the FAQ on 29 September 2026. The regulation it explains took effect on 30 September 2026.Source: OFAC, US Treasury
Source Material

Written with AI from Lowdown's published reporting. Not individually reviewed by an editor. Updated 22 October 2026. Editorial standards.