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Q. The entity with which I want to transact is not on the Cuba Restricted List, but its parent company is. Can I engage in a direct financial transaction with the subentity?

A. Yes. Entities or subentities that are owned or controlled by another entity or subentity on the Cuba Restricted List are not treated as restricted unless also specified by name on the list.

Q. Will there be updates to the Cuba Restricted List? If so, how will I know when there has been a change?

A. The Department intends to update the Cuba Restricted List periodically. Updates to the list will be published in the Federal Register and will also be available here on the State Department’s website.

Q. Are there any exceptions to the prohibition on direct financial transactions with an entity on the Cuba Restricted List?

A. Yes, the National Security Presidential Memorandum  (NSPM) called for several exceptions to the prohibition on direct financial transactions with restricted entities, which the Departments of Commerce and the Treasury have incorporated into their regulations.

Please see the Department of Treasury’s Office of Foreign Assets Control’s and the Department of Commerce’s Bureau of Industry and Security websites for additional FAQs on issues more closely related to their regulations:

U.S. Department of State

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