OFAC distinguishes bank inquiries from orders to send money to Cuba
An update to Frequently Asked Question 53 explains how to separate a request for information from an instruction to transfer money.
The Office of Foreign Assets Control updated Frequently Asked Question 53 on October 26, 2026, addressing bank inquiries and Cuba-related operations. The guidance forms part of OFAC responses for financial institutions and individuals. It focuses on distinguishing a question about a possible money transfer from an instruction requesting that the bank process one. The separation clarifies how initial contact between a customer and bank should be understood.
Asking a financial institution whether money can be sent to Cuba does not by itself amount to ordering the funds moved. The clarification addresses a bank's response when a customer asks about an operation related to a sanctioned country or person. Seeking guidance and submitting a payment instruction are different situations even when both concern a possible transfer. The FAQ addresses that difference.
The distinction matters because a transfer order may trigger sanctions-related obligations. The guidance separates that scenario from a preliminary inquiry and explains how an institution should approach questions about operations involving sanctioned countries or persons. The point is not to treat a question as an order but to identify what kind of request the customer makes and assess the appropriate banking response.
The updated answer is directed at financial institutions and people seeking guidance about these transfers. It offers a concrete standard for distinguishing asking about an operation from requesting that the bank execute it. That difference structures OFAC's explanation of inquiries and orders within financial sanctions. The update concerns how to interpret these interactions, not treating them as equivalent acts.