OFAC FAQ #752 · Cuba Sanctions
Do U.S. banking institutions need to apply for a specific license to release funds transfers or accounts previously blocked pursuant to the CACR that are now authorized by general license?
OFAC's answer
If a transaction was previously blocked pursuant to the [CACR](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515?toc=1) at the time of the transaction, and the CACR was later amended to allow similar transactions, the earlier transaction is not unblocked unless the CACR amendments include a general license that unblocks previously blocked funds. Transactions must be authorized pursuant to the CACR at the time that they are processed. To the extent that the unblocking of a funds transfer or blocked account is not authorized by a general license, a specific license would be required to release funds transfers or unblock accounts previously blocked.