What level of due diligence are internet-based service providers expected to conduct to determine whether the intended recipients of an export or reexport are prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party pursuant to 31 CFR § 515.578(b)(1)?
OFAC's answer
Section [515.578(b)(1)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.578) of the CACR excludes from authorization under [31 CFR 515.578(a)(1)-(3)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.578) the direct or indirect exportation or reexportation of services with knowledge or reason to know that such services are intended for a prohibited official of the Government of Cuba, as defined in [31 CFR § 515.337](https://www.ecfr.gov/current/title-31/section-515.337), a prohibited member of the Cuban Communist Party, as defined in [31 CFR § 515.338](https://www.ecfr.gov/current/title-31/section-515.338), or to organizations administered or controlled by the Government of Cuba or the Cuban Communist Party, except as specified in [31 CFR § 515.578(a)(4)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.578). For purposes of assessing whether exports or reexports are excluded from [31 CFR § 515.578](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.578) pursuant to [31 CFR § 515.578(b)(1)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.578), internet-based service providers subject to U.S. jurisdiction may reasonably rely on information provided to them by their customers in the ordinary course of business, unless they know or have reason to know a transaction is not authorized.