Short Answer
Yes, a U.S. company can export some goods and services to Cuba, but only in narrow authorized channels. The practical answer depends on the product, end use, Cuban buyer, payment route, shipping path, and whether OFAC or BIS licensing is required.
- Likely yes: informational materials, some telecom / internet services, certain agricultural or medical exports, and some support for genuinely private Cuban businesses when parties and payment routes screen clean.
- Maybe / get review: software, equipment, services, or MIPYME support where the importer, bank, logistics provider, or end user may touch the Cuban state sector. Use the process map next.
- Likely no: transactions involving SDN-listed parties, Cuba Restricted List entities, Cuban military-controlled companies, prohibited lodging, blocked payment routes, or state tourism counterparties.
Answer These Six Questions
- What are you exporting? Product, service, software, technology, or data.
- Who receives it? End user, importer, beneficial owner, bank, shipper, and delivery location.
- Why is it allowed? OFAC general license, specific license, statutory channel, or no authorization.
- Does BIS control it? ECCN / EAR99, Cuba license requirement, license exception, or no-license determination.
- Is anyone restricted? SDN, CRL, CPAL, GAESA, Gaviota, CIMEX, FINCIMEX, ETECSA, or military-control exposure.
- Can you execute it? Payment, shipping, insurance, records, and Cuban-side import channel are feasible.
Simple Result
- Green: product fits an authorized channel, parties screen clean, BIS path is clear, payment/shipping work, and records are retained.
- Yellow: possible, but you need counsel, ITA/BIS/OFAC guidance, a license, or missing counterparty ownership facts.
- Red: blocked party, military-controlled buyer, prohibited payment route, prohibited end use, or no defensible authorization path.