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Contradictions in OFAC Cuba Rules, Guidance Causing Compliance Confusion
By Brian Monroe
printA contradiction between U.S. sanctions rules and federal guidance on Cuban money remitters is prompting some compliance staff to scratch their heads, say analysts. In finalized regulations issued on September 3, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) stated that "depository institutions" can, under a new general licensing rule, act as remittance forwarders for funds sent to Cuba without obtaining a "specific license" from the agency, which can take months. Conflicting with that rule is a March 2006 Circular, or guidance, by OFAC stating that any U.S. depositary institution must be "specifically licensed" if it wants to...
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