Analysis
Section 516.101 makes this framework separate from the existing part 515 Cuba rules: authorization under another part does not authorize a transaction prohibited here. The text addresses blocked property, applicable ownership interests, licensing and correspondent-account restrictions under the executive order. Analysis: payment and sanctions teams need to identify the governing authority as well as the counterparty.
What remains uncertain
Publication does not itself designate every Cuban counterparty or impose identical restrictions on every foreign bank. Actual blocking, account restrictions and exceptions depend on the operative authority and relevant OFAC action. The appended executive order also preserves specified part 515-authorized activities; do not read the new framework as blanket cancellation of existing licenses.
Sources
- Federal Register — Cuba Sanctions Regulations ↗Official source