OFAC FAQ #726 · Cuba Sanctions
In the case of a customer traveling to or from Cuba under a specific license, may providers of carrier and travel services collect and retain on file the specific license number in lieu of a physical or electronic copy of the license?
OFAC's answer
Yes. OFAC allows persons subject to U.S. jurisdiction providing authorized carrier or travel services to a customer traveling under a specific license to maintain either the specific license number or a copy of the license on file. See [31 CFR § 515.572](https://www.ecfr.gov/cgi-bin/text-idx?SID=d52a067bc774495c1252a6777a110a74&mc=true&node=se31.3.515_1572&rgn=div8)(b)(1) Persons subject to U.S. jurisdiction providing authorized carrier or travel services that choose to collect the specific license number in lieu of the license must maintain a record of that number, as well as the other required information set forth in § 515.572(b), for at least five years.