OFAC FAQ #786 · Cuba Sanctions
Is “peering” — an arrangement of traffic exchange between internet networks — authorized by the CACR?
OFAC's answer
Yes. For example, a U.S. company could enter into a peering arrangement with ETECSA, the Cuban telecommunications provider, for the provision of internet services. See [§ 515.542(b)](https://gov.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.542).