All fund flows to a recipient under any OFAC related exemption to a sanctioned country must meet the qualifying criteria.

i) the requirements do not extend beyond the original intended recipient and purpose. So for instance, if the flow were a payment to an entrepreneur in Cuba, and the entrepreneur then used the funds to pay an employee, who then used the funds to buy bananas from a grocery store owned by an individual or entity on the SDN list, the flow does not fail due to the grocer not meeting the exemption requirements;

ii) neither the regulations nor the regulatory guidance impose strict verification requirements for meeting the independent entrepreneur flow exemption;

iii) independent entrepreneurs include:

• online services operated by independent entrepreneurs
• freelancers offering services online
• independent peer-to-peer services, networks, and protocols
• entities licensed in Cuba as private enterprises, i.e. PYMES
• independent decentralized entities, i.e. DAOs
• verification of independent entrepreneur status can be done via personal knowledge, social media, and/or KYC policy.