OFAC Clarifies Authorization Surrounding Digital Payment Remittances to Cuba

People subject to U.S. jurisdiction can send remittances to Cuba through digital payments in certain situations, the Office of Foreign Assets Control said in a new frequently asked question this week. OFAC said remittances involving digital payments -- including money transfers through credit cards and digital bank accounts -- are permissible if the transaction is authorized under the Cuban Assets Control Regulations and if the digital payment service provider is a “U.S.-registered money transmitter or other qualifying banking institution.”

The agency stressed that a bank is “expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures.” But OFAC also said banks may “rely on the statements of their customers” that certify that the remittance transaction is authorized, unless the bank knows or has reason to know the transaction isn’t authorized. U.S. people and other institutions may apply for a specific license if they think their transaction falls outside the scope of this authorization.