OFAC updated its Comprehensive Guidelines for License Applications to Engage in Travel-Related Transactions Involving Cuba (the “Application Guidelines") to reflect changes made to the licensing criteria set forth in the section of the Application Guidelines pertaining to educational exchanges not involving academic study pursuant to a degree program (also known as people-to-people exchanges)(31 CFR Part 515, Section 515.565(b)(2)). The Application Guidelines are intended to assist persons who wish to engage in travel-related transactions involving Cuba in making their own determinations as to whether their activities are authorized by a general license (in which case no specific license from OFAC is needed), or their activities could be authorized by a specific license from OFAC (in which case an application is required).
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