Cuba Export Controls and Sanctions Process Map
A practical route map for U.S. exporters: before you quote, ship, finance, or meet a Cuban counterparty, walk the opportunity through the Cuba sanctions and export-control stack.
Start With This Answer
A Cuba export is not actionable until it clears four gates: OFAC authorization, BIS product / technology controls, restricted-party screening, and executable payment / shipping. If one gate is unknown, the answer is yellow until it is resolved.
- Use Can my U.S. company export to Cuba? if you need the quick green / yellow / red classification first.
- Use OFAC Cuba General License Lookup to find the possible CACR authorization basis.
- Use Cuba Restricted List checker and OFAC Cuba Sanctions Exposure Checker before any outreach.
Before taking action
- Define the transaction, product, service, software, technology, end use, and every party.
- Identify the OFAC general license, OFAC specific license path, or reason the activity is not authorized.
- Check product / technology controls through BIS and document ECCN / EAR99 thinking.
- Screen names, parents, owners, addresses, hotels, vessels, aircraft, banks, and payment intermediaries.
- If any answer is yellow, contact Cuba country contacts, ITA Trade Americas, BIS, OFAC, or counsel before quoting or shipping.
- Keep records for the full required retention period.
OFAC CACR vs BIS EAR: Jurisdiction Quick Reference
Cuba exports face two parallel regulatory stacks. Both apply independently — clearing one does not clear the other.
| Feature | OFAC — CACR (31 CFR Part 515) | BIS — EAR (15 CFR Parts 730–774) |
|---|---|---|
| Agency | U.S. Treasury — Office of Foreign Assets Control | U.S. Commerce — Bureau of Industry and Security |
| What it controls | Financial transactions, trade, and travel with Cuba (broad economic embargo) | Dual-use goods, software, and technology by ECCN classification |
| Cuba designation | Cuba is a CACR-sanctioned country | Cuba is Country Group E:2 (embargoed) |
| Authorization path | General license (self-certify) or OFAC-issued specific license | License exception or BIS license application |
| Clearing one clears the other? | No. CACR authorization does not satisfy BIS/EAR, and vice versa. Both must be satisfied independently before export. | |
OFAC General License vs Specific License: When to Use Which
| Feature | General License (GL) | Specific License (SL) |
|---|---|---|
| How granted | Written into CACR regulations — self-certify if you qualify | Applied for individually; OFAC issues written authorization |
| Advance OFAC approval | None needed — proceed if conditions are met | Yes — must receive written approval before acting |
| Examples | Agricultural exports (§515.533), support for Cuban people (§515.574), telecom (§515.578) | Transactions not covered by any GL; novel business models; Cuban government counterparties |
| Timeline | Immediate (if you qualify) | Weeks to months — OFAC review period required |
| Use when | Your transaction fits an established GL category cleanly | No GL covers your transaction, or the activity is borderline / high-stakes |
Browse all Cuba general licenses: OFAC Cuba General License Lookup.
Use Next
Internal tools that make this page actionable.
Screen Internally
Cuban Insights checks to run before outreach or shipment.
Official Contacts & Sources
Use these for counseling, authority, and source-of-truth checks.
ITA Attribution
This product uses International Trade Administration data and Trade.gov content but is not endorsed or certified by the International Trade Administration.
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