How does the September 30, 2026 amendment to the Cuban Assets Control Regulations (CACR) affect those previously authorized "U-turn" transactions in which Cuba or a Cuban national has an interest?
OFAC's answer
Effective September 30, 2026, OFAC amended [31 CFR § 515.584(d)](https://www.ecfr.gov/current/title-31/part-515/section-515.584) by removing the authorization for banking institutions subject to U.S. jurisdiction to process transactions that originate and terminate outside the United States, provided that neither the originator nor the beneficiary was a person subject to U.S. jurisdiction (the "U-turn general license"). Pursuant to [31 CFR § 515.584(d)](https://www.ecfr.gov/current/title-31/part-515/section-515.584), banking institutions subject to U.S. jurisdiction are now only authorized to reject (vice block) such transactions. To account for the removal of the "U-Turn" authorization, OFAC also amended [§ 515.584(e)](https://www.ecfr.gov/current/title-31/part-515/section-515.584) to remove the authorization for the unblocking and return of any transfer that would have been authorized pursuant to the prior "U-Turn" general license.