On September 30, 2026, OFAC amended 31 CFR § 515.565(a) to restore particular requirements for authorized educational activities related to Cuba. As of September 30, 2026, the requirements related to a person's use of the educational activities- authorization depend on whether the person engaging in the activity is associated with an accredited U.S. undergraduate or graduate degree-granting academic institution.
Effective September 30, 2026, § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate degree-granting academic institutions and their faculty, staff, and students, to engage in the travel-related transactions set forth in 31 CFR § 515.560(c) and such additional transactions as are directly incident to the six categories of educational activities enumerated in § 515.565(a)(1). Among other educational activities, this general license authorizes, subject to conditions outlined in § 515.565(a)(1), faculty, staff, and students at accredited U.S. undergraduate or graduate degree-granting academic institutions to participate in a structured educational program in Cuba or to teach at a Cuban academic institution, as well as authorizes Cuban scholars to engage in certain educational activities in the United States. For a complete description of authorized educational activities related to accredited U.S. undergraduate or graduate degree-granting academic institutions, and the restrictions that apply, see § 515.565(a)(1).
Effective September 30, 2026, § 515.565(a)(2) authorizes persons subject to U.S. jurisdiction, including, for example, U.S. secondary schools, to engage in additional educational activities that are not authorized under § 515.565(a)(1), provided that: (1) any travel-related transactions pursuant to these authorizations take place under the auspices of an organization that is a person subject to U.S. jurisdiction (the "sponsoring organization"), and (2) all travelers are accompanied by a person subject to U.S. jurisdiction who is an employee, paid consultant, agent, or other representative of the sponsoring organization (subject to certain exceptions). These authorized transactions include the travel-related transactions set forth in § 515.560(c) and such transactions as are directly incident to the 12 categories of educational activities enumerated in § 515.565(a)(2). For example, under this general license, U.S. and Cuban universities may engage in academic exchanges and joint non-commercial academic research, and persons subject to U.S. jurisdiction may provide standardized testing services and certain internet-based courses to Cuban nationals. For a complete description of what this general license authorizes and the restrictions that apply, see § 515.565(a)(2).
Effective September 30, 2026, OFAC further amended § 515.565 to remove the authorization for group people-to-people educational travel.
Please note that the general license at § 515.565 excludes any direct or, effective September 30, 2026, indirect financial transaction with entities and subentities identified on the State Department's Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see § 515.209. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.