The CACR issued by OFAC and taking effect Sept 21 states:
Remittances. OFAC is amending section 515.570(b) to remove the limitation on
donative remittances to Cuban nationals who are not prohibited officials of the Government of Cuba
or prohibited members of the Cuban Communist Party. OFAC also is amending section 515.560(c)(4)(i)
to remove the limitation on certain authorized remittances that authorized travelers may carry to
Cuba, and section 515.560(d)(2) to remove the limitation on the amount of remittances that a Cuban
national permanently resident in Cuba who is departing the United States may carry to Cuba.
The Federal Register states: Any depository institution, as defined in § 515.333, that is a person subject to U.S. jurisdiction
is authorized to:Provided that neither the originator nor the beneficiary is a person subject to U.S. jurisdiction, process funds transfers originating and terminating outside the United States relating to transactions that would be authorized pursuant to this part if the originator or beneficiary were a person subject to U.S. jurisdiction.
So if we receive a wire from a client, to someone located in Cuba, can we process it without any further paper work as long as the individuals are not prohibited officials of the Government of Cuba or prohibited members of the Cuban Communist Party?