771. May a person subject to U.S. jurisdiction provide training to a Cuban distributor or customer on the use of goods authorized for export to Cuba by the Department of Commerce?

Yes. OFAC considers the provision of training to persons in Cuba, including to Cuban nationals, on the use of items authorized for export or reexport to Cuba by the Department of Commerce to be ordinarily incident to the export or reexport of the item and therefore authorized by 31 CFR § 515.533(a). Persons subject to U.S. jurisdiction are authorized, subject to certain conditions, to travel to Cuba to provide such training. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.533(c)(1). Please note that OFAC amended 31 CFR § 515.533 to exclude 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. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. The exportation or reexportation to Cuba of technology subject to the EAR may require separate authorization from the Department of Commerce.