Cuba Assets and Travel Face New Treasury Limits
Published Date: 9/30/2026
Rule
Summary
Starting September 30, 2026, new rules tighten U.S. financial and travel dealings with Cuba. If you’re a business or traveler, you can’t do indirect money transactions with certain Cuban groups, and some travel options like group tours and professional meetings are now off-limits. These changes follow the President’s updated Cuba policy and aim to strengthen U.S. control while impacting how money and visits flow to Cuba.
Analyzed Economic Effects
8 provisions identified: 2 benefits, 5 costs, 1 mixed.
Ban on indirect payments to Cuba-listed entities
Starting September 30, 2026, persons subject to U.S. jurisdiction may not participate in indirect financial transactions when either the originator or ultimate beneficiary is an entity or subentity on the State Department's Cuba Restricted List. An "indirect financial transaction" is defined as taking part in a funds transfer without acting as the originator or the ultimate beneficiary. The rule preserves limited exceptions for travel-related transactions and for commercial engagements that were in place before the named entity or subentity was added to the Cuba Restricted List.
U‑Turn transfers for Cuba ended
As of September 30, 2026, U.S.-jurisdiction banking institutions are no longer authorized to process so-called "U-Turn" funds transfers that originate and terminate outside the United States where neither the originator nor the beneficiary is a U.S. person; banks are instead authorized to reject such transfers. OFAC also removed the earlier authorization to unblock and return transfers that would have been processed under the old U-Turn authorization.
Banks can no longer open certain Cuban entrepreneur accounts
Starting September 30, 2026, the authorization allowing U.S.-jurisdiction banking institutions to open and maintain accounts solely in the name of a Cuban national who is an "independent private sector entrepreneur" (as defined in the Regulations) is removed. Banking institutions will now need a specific OFAC license to unblock funds located in such accounts.
Tighter education and group travel rules to Cuba
Effective September 30, 2026, general authorizations for group people-to-people educational travel are removed and authorizations to attend or organize professional meetings or conferences in Cuba via general license are eliminated. Educational travel is narrowed: accredited U.S. undergraduate or graduate degree-granting institutions, their enrolled students, and full-time permanent employees may engage in certain educational activities (many requiring at least 10 weeks in Cuba), while other educational activities must occur under a U.S.-jurisdiction sponsor and travelers must be accompanied by a representative of that sponsor. Travelers who completed at least one travel-related transaction (e.g., bought a flight or reserved lodging) prior to September 30, 2026 can rely on grandfathering provisions; persons in Cuba for professional meetings on September 30, 2026 may remain and engage in authorized wind-down transactions only until October 30, 2026 and must depart by that date.
Remittances to students in Cuba allowed under conditions
Persons 18 years or older may make remittances to close relatives who are students in Cuba under a general educational license (Sec. 515.565(a)) or an applicable specific license, provided the remittances are not made from a blocked source and are used to fund transactions authorized by that license. This rule appears in the remittances section (Sec. 515.570(d)).
Limits on processing U.S. dollar instruments tied to Cuba
Effective September 30, 2026, persons subject to U.S. jurisdiction may not accept, process, or give value to U.S. dollar monetary instruments presented indirectly by Cuban financial institutions if the transaction would be a direct or indirect financial transaction with an entity or subentity on the Cuba Restricted List. OFAC deleted a prior note that had allowed certain indirect processing under previous rules.
Case-by-case licenses remain available
Although general licenses for some professional meetings and certain educational or research travel were removed, OFAC may still issue specific (case-by-case) licenses authorizing travel-related transactions for professional research or professional meetings that are not covered by a general license. Specific licenses for wind-down and refunds related to professional meetings are authorized through October 30, 2026 for persons in Cuba on September 30, 2026.
Exceptions preserved for certain exports and services
The rule clarifies that certain financial transactions related to exports or reexports remain authorized despite other restrictions: exports or reexports of agricultural commodities, medicines or medical supplies, items associated with telecommunications and internet services for the Cuban people, and items associated with air and sea operations that support permissible travel, cargo, or trade are excepted from some prohibitions on direct or indirect financial transactions.
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