Are remittance forwarding service providers required to independently verify that a sender’s family or donative remittance is authorized when processing such remittances?
OFAC's answer
No. Under [31 CFR § 515.572(a)(3)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.572), banking institutions, as defined in [§ 515.314](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-C/section-515.314), including U.S.-registered brokers or dealers in securities and U.S.-registered money transmitters, are authorized to provide services in connection with the collection, forwarding, or receipt of remittances authorized pursuant to the CACR, subject to certain conditions. In addition, under [§ 515.570(h)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.570), banking institutions are authorized to unblock and return blocked remittances that would have been authorized under [§ 515.570(a) or (b)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.570). Banking institutions may rely on the statements of their customers that remittance transactions are authorized unless they know or have reason to know a transaction is not authorized. A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures with respect to a transaction involving Cuba or a Cuban national.