According to this week's news, US Secretary of State has removed the Republic of Cuba from the list of State Sponsors of Terrorism, as the 45-day period for Congressional objections having expired, and no action was taken. That being said, compliance officers should stress to their bank customers that this is a removal of Cuba from the terrorist facilitators list, not a deletion of the terrorist organizations from OFAC and other sanctions lists.
Cuba may have persuaded State that it no longer promotes terrorist organizations, but it has not expelled their members from Havana, nor has it closed their offices. Be alert, and thoroughly check any and all individuals who are inside Cuba, when it comes to your bank clients' moves to conduct or establish businesses inside Cuba. You do not want any FARC, ELN or ETA agents as your clients' business partners, local representatives, or agents in Cuba. You also need to be aware that Hezbollah, Hamas and several other smaller Palestinian terrorist groups, all have relationships with Cuba, and have agents resident there, and they communicate with their other cells, in Venezuela, where they are raising money through drug trafficking. Disregard Cuba's statements about how it no longer supports these terrorist organizations; those groups are still operating in Cuba.