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702. What constitutes “educational activities” for generally authorized travel and other transactions?

Answer

Persons subject to U.S. jurisdiction, including U.S. academic institutions and their faculty, staff, and students, are authorized 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 12 categories of educational activities, as described in § 515.565(a).  Among other things, this general license authorizes, subject to conditions, faculty, staff, and students at U.S. academic institutions and secondary schools to engage in certain educational activities, including study abroad programs, in Cuba, Cuban scholars to engage in certain educational activities in the United States, and certain activities to facilitate licensed educational programs. U.S. and Cuban universities may engage in academic exchanges and joint non-commercial academic research under the general license.  This provision also authorizes persons subject to U.S. jurisdiction to 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.

In addition, a general license at § 515.565(b) authorizes, subject to conditions, group people-to-people educational travel conducted under the auspices of an organization that is subject to U.S. jurisdiction and that sponsors such exchanges to promote people-to-people contact, provided such travelers are accompanied by an employee, paid consultant, or agent of the sponsoring organization.  See FAQ 704.

Please note that this general license excludes direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List.  For a description of the scope of the prohibition on direct 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

Updated: June 08, 2022

Date Released
September 23, 2020