Financial Intelligence
Persons subject to U.S. jurisdiction may not travel to Cuba to engage in “people-to-people” educational exchanges on an individual basis. However, group people-to-people travel is generally authorized for educational activities, subject to certain conditions. Effective June 9, 2022, OFAC amended 31 CFR § 515.565(b) to authorize 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. Travel-related transactions authorized pursuant to § 515.565(b) must be for the purpose of engaging, while in Cuba, in a full-time schedule of activities that are intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities; and will result in meaningful interactions with individuals in Cuba.
For a complete description of what this general license authorizes and the restrictions that apply, see § 515.565.
The export or reexport to Cuba of items subject to the Export Administration Regulations (15 CFR parts 730 through 774), including vessels and aircraft used to provide carrier services, may require separate authorization from the Department of Commerce, Bureau of Industry and Security (BIS). See § 515.533. For additional information regarding BIS’s export controls, see BIS’s Cuba webpage.
Updated: June 08, 2022
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
31 CFR § 515.564 (a)(1) contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to professional research in Cuba. Among other things, this general license authorizes, subject to conditions, professional research in Cuba relating to a traveler’s profession, professional background, or area of expertise.
Effective June 9, 2022, OFAC amended § 515.564(a) to include a general license authorizing, subject to conditions, travel-related and other transactions incident to attendance at or organization of professional meetings or conferences in Cuba. This general license authorizes persons subject to U.S. jurisdiction to travel to Cuba for purposes of attending or organizing professional meetings or conferences, such as meetings or conferences to support expanded internet access and remittance processing companies and to provide additional support and training to independent Cuban entrepreneurs.
Please note that these general licenses 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 § 515.210. The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule of professional research or a full-time schedule of attendance at, or organization of, professional meetings or conferences, respectively. An entire group does not qualify for the general license merely because some members of the group qualify individually. For a complete description of what these general licenses authorize and the restrictions that apply, see § 515.564.
Updated: June 08, 2022
Travel-related transactions are permitted by general or specific licenses for certain travel related to the 12 categories of activities identified in 31 CFR § 515.560(a). Those travel-related transactions permitted by general license, subject to specified criteria and conditions, include: family visits; official business of the U.S. government, foreign governments, and certain intergovernmental organizations; journalistic activity; professional research and professional meetings; educational activities; religious activities; athletic competitions by amateur or semi-professional athletes or athletic teams; support for the Cuban people; humanitarian projects; activities of private foundations or research or educational institutes; exportation, importation, or transmission of information or information materials; and certain authorized export transactions. Each person relying on a certain general authorization must retain specific records related to the authorized travel transactions. See §§ 501.601 and 501.602 of the Reporting, Procedures and Penalties Regulations for applicable recordkeeping and reporting requirements.
Effective June 9, 2022, OFAC amended § 515.564(a) to include a general license authorizing, subject to conditions, persons subject to U.S. jurisdiction to travel to Cuba for purposes of attending or organizing professional meetings or conferences in Cuba. OFAC also amended § 515.565 to remove certain restrictions on authorized academic educational activities (§ 515.565(a)) and to authorize 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 (§ 515.565(b)). Travel-related transactions authorized pursuant to § 515.565(b) must be for the purpose of engaging, while in Cuba, in a full-time schedule of activities that are intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities; and will result in meaningful interactions with individuals in Cuba. This amendment does not authorize individual people-to-people travel. Travel for tourist activities is not permitted.
The CACR continue to include the prohibition added on November 9, 2017 that restricts certain 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.
Also, the CACR continue to include a prohibition added on September 24, 2020 at § 515.210, which prohibits any person subject to U.S. jurisdiction from lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property that the Secretary of State has identified as a property in Cuba that is owned or controlled by: the Cuban government; a prohibited official of the Government of Cuba, as defined in § 515.337; a prohibited member of the Cuban Communist Party, as defined in § 515.338; a close relative, as defined in § 515.339, of a prohibited official of the Government of Cuba, or a close relative of a prohibited member of the Cuban Communist Party, when the terms of the general or specific license expressly exclude such a transaction. The State Department maintains the Cuba Prohibited Accommodations List, which identifies the names, addresses, or other identifying details, as relevant, of properties identified as meeting such criteria.
Updated: June 08, 2022