Are specific licenses still required for transactions relative to the administration of a Cuban estate?
OFAC's answer
Section 515.523 of the Cuban Assets Control Regulations authorizes all transactions incident to the administration and distribution of the assets of a blocked estate of a decedent. All property distributed pursuant to 31 CFR § 515.523 is unblocked, provided that neither Cuba nor a Cuban national (other than the decedent or a person unblocked pursuant to 31 CFR § 515.505) has an interest in the property. For a complete description of what this general license authorizes and the restrictions that apply, please see 31 CFR § 515.523. Furthermore, funds deposited in a blocked account in a banking institution in the United States held in the name of, or in which the beneficial interest is held by, a national of Cuba as a result of a valid testamentary disposition, intestate succession, or payment from a life insurance policy or annuity contract triggered by the death of the policyholder or contract holder may be remitted to the national of Cuba pursuant to 31 CFR § 515.570(f)(1). For a complete description of what this general license authorizes and the restrictions that apply, please see 31 CFR § 515.570(f). Please note, effective November 26, 2020, 31 CFR § 515.570 no longer authorizes any transaction relating to the collection, forwarding, or receipt of remittances involving an entity or subentity identified on the [State Department’s Cuba Restricted List.](https://www.state.gov/cuba-sanctions/cuba-restricted-list/)