OFAC FAQ #750 · Cuba Sanctions
If a Cuban national resident in the United States has applied to become a lawful permanent resident alien of the United States, does that individual have to apply to OFAC to be treated as an unblocked national?
OFAC's answer
No. If a Cuban national has taken up residence in the United States and has applied to become a lawful permanent resident alien of the United States and has an adjustment of status application pending, then the Cuban national is considered unblocked and does not need to apply to OFAC to be treated as an unblocked national, provided that he or she is not a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist party. See [31 CFR § 515.505(a)(1)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.505).