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There are a few recent questions relating traveling to Cuba as a European citizen, such as this one and this one. These however are with flights terminating in Cuba, with the intention to stay in Cuba.

Do the same restrictions apply for Europeans having merely a layover in Cuba? The closest related answer is for US citizens, which I not the same.

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    AFAIK, the US to Cuba travel restrictions only apply to US citizens (possibly also to permanent residents, although I’m not sure on that point). See this answer travel.stackexchange.com/questions/120223/…
    – Traveller
    Feb 14 '19 at 20:09
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    Funny, I was just going to link to exactly that answer. None of this applies to you, if you are not a citizen or resident of the USA. That said, this is a very strange flight routing. I hope it was very cheap...
    – Michael Hampton
    Feb 14 '19 at 22:09
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    @Traveller What about this from travel.state.gov, as in the first question I linked? "Travel to Cuba is regulated by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury. Anyone located in the United States, regardless of citizenship and nationality, must comply with these regulations." Does 'anyone located' imply US residents as opposed to 'just currently present in'?
    – Mitchell van Zuylen
    Feb 14 '19 at 23:22
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The Cuba sanctions are under 31 CFR § 515 and the relevant part is:

31 CFR § 515.560 - Travel-related transactions to, from, and within Cuba by persons subject to U.S. jurisdiction

Well, are you subject to U.S. jurisdiction?

31 CFR § 515.329 - Person subject to the jurisdiction of the United States; person subject to U.S. jurisdiction.

(b) Any person within the United States as defined in § 515.330;

31 CFR § 515.330 - Person within the United States

(1) Any person, wheresoever located, who is a resident of the United States;
(2) Any person actually within the United States;

That's crystal clear. The restrictions apply not only to citizens and residents but to anyone within the US. And the restrictions (first link) do not recognize a layover as a valid activity.

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    So it seems like persons transiting through Cuba must have an intermediary stop between Cuba and the US (in either direction), regardless of their citizenship.
    – Roddy of the Frozen Peas
    Sep 6 '19 at 0:13
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    Yes and Cancun itself would be a popular and sensible choice (or Canada, likely Toronto).
    – chx
    Sep 6 '19 at 0:39

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