To support the development of private businesses, and operation of economic activity in the non-state sector by self-employed individuals, as defined in § 515.340
**Entities:**
The authorized services pursuant to 31 CFR 515.582 are services supplied by an independent Cuban entrepreneur in Cuba, as demonstrated by documentary evidence. Persons subject to U.S. jurisdiction engaging in import transactions involving services supplied by an independent Cuban entrepreneur pursuant to § 515.582 are required to obtain documentary evidence that demonstrates the entrepreneur’s independent status, such as a copy of a license to be self-employed issued by the Cuban government or, in the case of an entity, evidence that demonstrates that the entrepreneur is a private entity that is not owned or controlled by the Cuban government. Supply of services must comply with other applicable state and federal laws.
Definition of Independent Entrepreneur: “...evidence that demonstrates that the entrepreneur is a private entity that is not owned or controlled by the Cuban government.” see https://www.state.gov/the-state-departments-section-515-582-list/
Related guidance from US Treasury indicates a financial institution does not need to independently perform verification and can accept certification from its customer that it met applicable requirements “... unless the financial institution knows or has reason to know….” that the requirements were not met: see FAQ #753. https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1541
$QVA Community Commentary on OFAC Regulations (Not Legal Advice!)