The export or reexport to Cuba of items subject to the EAR, including commercial vessels used to provide carrier services and private vessels, requires separate authorization from the Department of Commerce. See 31 CFR § 515.533. For a complete description of BIS’s regulatory requirements, see BIS’s Cuba webpage.
While 31 CFR § 515.572 generally authorizes the provision of carrier services, and 31 CFR § 515.572(a)(4) generally authorizes the provision of lodging services by persons subject to U.S. jurisdiction who are authorized to provide carrier services, OFAC amended its regulations effective June 5, 2019 to highlight the BIS requirements. For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR § 515.572.