Minimum compliance file
- Product / service description and classification rationale.
- End user, beneficial owner, importer, bank, logistics provider, vessel, and hotel if travel is involved.
- OFAC authorization basis or license request path.
- BIS classification and license analysis.
- SDN, CRL, CPAL, and known Cuban military-control screening results.
- Payment, shipping, and recordkeeping plan.
Traffic-light result
- Green: authorized path, clean parties, feasible payment, records retained.
- Yellow: possible path but needs counsel, license, or missing counterparty data.
- Red: blocked party, blocked category, prohibited payment route, or no defensible authorization.