Effective September 30, 2026, OFAC narrowed the authorization for persons subject to U.S. jurisdiction, including U.S. academic institutions and their faculty, staff, and students, to engage in certain education-related transactions involving Cuba. Persons subject to U.S. jurisdiction that wish to engage in educational activities, including travel-related transactions, involving Cuba must now fit within one of these categories:
- Educational Activities by Accredited U.S. Undergraduate or Graduate-Degree Granting Institutions: 31 CFR § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate-degree granting institutions, their students, and full time permanent employees to engage in certain educational activities, such as noncommercial research in Cuba specifically related to Cuba and for the purpose of obtaining a graduate degree, under the auspices of the academic institution without accompaniment by a representative from a sponsoring organization.
- Educational Activities by Other Institutions: § 515.565(a)(2) authorizes certain educational activities not authorized under § 515.565(a)(1), such as certain educational exchanges sponsored by Cuban or U.S. secondary schools, provided that the activity takes places under the auspices of an organization subject to U.S. jurisdiction and that all travelers are accompanied by a representative of the sponsoring organization.
Additionally, OFAC removed the previous authorization at § 515.565(b) for group people-to-people educational travel.
OFAC replaced these education-related authorizations with "grandfathering" provisions authorizing certain educational travel and group people-to-people educational travel that previously was authorized under § 515.565(a) and § 515.565(b), respectively, where the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to September 30, 2026.