OFAC FAQ #754 · Cuba Sanctions
Is the U.S. originating bank or U.S. beneficiary bank required to independently verify that a person subject to U.S. jurisdiction is not engaging in a direct financial transaction as defined in § 515.209 when processing Cuba-related transactions?
OFAC's answer
No. To the extent the transaction involves an entity or subentity on the [Cuba Restricted List](https://www.state.gov/cuba-sanctions/cuba-restricted-list/), a financial institution can rely on the statements of its customer that the transaction is authorized unless it knows or has reason to know the transaction is not authorized. A financial institution is expected to do its normal due diligence with respect to a transaction involving Cuba or a Cuban national.