Generally, no. Effective June 5, 2019, there is no general license authorizing people-to-people educational activities in Cuba. The term “people-to-people travel” refers to an authorization that previously existed in the CACR, subject to conditions, for persons subject to U.S. jurisdiction to engage in certain educational exchanges in Cuba on an individual basis or under the auspices of an organization that is a person subject to U.S. jurisdiction and sponsors such exchanges to promote people-to-people contact.
On November 9, 2017, in accordance with NSPM-5, OFAC amended the general license for people-to-people educational activities in Cuba to remove the authorization for individual people-to-people educational travel. Effective June 5, 2019, in further accordance with the President’s foreign policy toward Cuba announced in April 2019, OFAC removed the authorization for group people-to-people educational travel in § 515.565(b). There is a grandfather clause in § 515.565(b) that authorizes certain group people-to-people educational travel that previously was authorized where the traveler had completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to June 5, 2019. 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.
For purposes of that grandfather clause only, an “organization” is an entity subject to U.S. jurisdiction that sponsors educational exchanges that do not involve academic study pursuant to a degree program and that sponsors such exchanges to promote people-to-people contact. To the extent proposed travel falls within the scope of the grandfather clause for group people-to-people educational travel, organizations subject to U.S. jurisdiction may proceed with sponsoring such travel without applying to OFAC for a specific license. It is OFAC’s policy not to grant applications for a specific license authorizing transactions where a general license is available. OFAC will apply a policy of denial with respect to applications for a specific license authorizing prohibited people-to-people travel and related transactions effective June 5, 2019.
For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.565.
The export or reexport to Cuba of items subject to the EAR, including vessels and aircraft used to provide carrier services, requires separate authorization from the Department of Commerce. See 31 CFR § 515.533. For additional information regarding BIS’s latest travel-related amendments, see BIS’s Cuba webpage.