OFAC FAQ #742 · Cuba Sanctions
Are financial institutions other than banks permitted to open correspondent accounts in Cuba?
OFAC's answer
Depository institutions, as defined in [31 CFR § 515.333](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-C/section-515.333), which include certain financial institutions other than banks, are permitted to open correspondent accounts at banks in Cuba. See [31 CFR § 515.584(a)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.584).