Process map · OFAC + BIS

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.

Process map ITA / Trade.gov U.S. exporters OFAC + BIS + State screening

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.

Before taking action

  1. Define the transaction, product, service, software, technology, end use, and every party.
  2. Identify the OFAC general license, OFAC specific license path, or reason the activity is not authorized.
  3. Check product / technology controls through BIS and document ECCN / EAR99 thinking.
  4. Screen names, parents, owners, addresses, hotels, vessels, aircraft, banks, and payment intermediaries.
  5. If any answer is yellow, contact Cuba country contacts, ITA Trade Americas, BIS, OFAC, or counsel before quoting or shipping.
  6. Keep records for the full required retention period.

Use Next

Internal tools that make this page actionable.

Can my U.S. company export to Cuba? Start here if you do not yet know whether the activity is green, yellow, or red. Cuba export compliance checklist Turn the process map into a file-ready compliance checklist. Cuba country contacts directory Find the right official contact path after the U.S.-side issue list is clear.

Screen Internally

Cuban Insights checks to run before outreach or shipment.

OFAC Cuba General License Lookup Find the CACR section that could authorize the activity. OFAC Cuba Sanctions Exposure Checker Search names, companies, vessels, aircraft, or aliases against the Cuba SDN list. Cuba Restricted List checker Screen GAESA, Gaviota, CIMEX, FINCIMEX, Habaguanex, and other restricted entities. Public company Cuba exposure check Use when a U.S.-listed counterparty, supplier, bank, or logistics provider is involved.

Official Contacts & Sources

Use these for counseling, authority, and source-of-truth checks.

ITA Trade Americas contact page Use for regional export counseling and Commercial Service routing. ITA Market Intelligence search Use for official U.S. government market notes and sector signals. BIS export controls guidance Use for EAR, ECCN, license, and export-control questions. OFAC Cuba sanctions program Use for CACR, sanctions, general licenses, and Cuba program guidance.

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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