Frequently Asked Questions

701. What constitutes generally authorized travel-related transactions for “professional research” in Cuba?

Answer

Section 515.564 (a)(1) of the CACR 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. In accordance with NSPM-5, OFAC amended this general license to exclude from the authorization direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List.

Also, and effective September 24, 2020, OFAC amended this general license 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 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. 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 this general license authorizes and the restrictions that apply, see 31 CFR § 515.564. 

On September 24, 2020, OFAC eliminated the general license previously contained in §515.564(a)(2) for travel-related transactions and other transactions that are directly incident to attendance at, or organization of, professional meetings or conferences in Cuba. Persons subject to U.S. jurisdiction are no longer generally authorized to attend or organize professional meetings or conferences in Cuba pursuant to this section. OFAC amended § 515.564 to clarify that specific licenses may be issued on a case-by-case basis authorizing the travel-related transactions in § 515.560(c) and other transactions that are related to professional research in Cuba that do not qualify for the general license under 515.564(a) or professional meetings or conferences in Cuba that are not authorized under other travel-related authorizations and that relate to activities otherwise authorized pursuant to the CACR.
 

 

Date Released
September 23, 2020