OFAC FAQ #741 · Cuba Sanctions
Can U.S. financial institutions, including their foreign branches and foreign-incorporated subsidiaries, permit the use of credit and debit cards they issue by, and process credit and debit card transactions for, third-country nationals whose travel to, from, or within Cuba may not fall within the 12 categories of authorized travel?
OFAC's answer
Yes. Section [515.584(c)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.584) of the CACR authorizes all transactions incident to the processing and payment of credit and debit cards transactions for third-country nationals traveling to, from, or within Cuba. Any person subject to U.S. jurisdiction, including U.S. financial institutions and their foreign branches, may conduct transactions authorized by this section.