The United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) has released an updated list of authorized providers of travel, airfare, and remittance services to Cuba. OFAC had recently updated this list, however, there have been some changes that have warranted the issuing of a new list.

Those traveling to Cuba under a general license or specific license need to make sure that the service provider they use for either their travel arrangements or their air travel is on the list released by OFAC. There are a number of reasons for the issuance of a specific license authorizing travel to Cuba. Some of these reasons include travel for religious purposes, educational purposes, humanitarian relief efforts, participation in athletic or sporting events, journalistic activities, and activities related to one’s profession, such as attending a conference.

While it may seem that it is easy to obtain a specific license to travel to Cuba under one of the aforementioned reasons it is not. The Cuban Assets Control Regulations (“CACR”) must be read very careful to determine whether or not an individual can obtain a specific license to travel to Cuba. Many of the regulations require that if an applicant cites a certain specific reason for requesting a license, that the individual must be engaged in the activity cited for the majority of their time there. For example, if you wish to apply under the regulation for specific licensure pursuant to educational activities, it may require you to be in school in Cuba as part of a graduate study of program and/or remain there for up to five weeks or more.

Like all economic sanctions programs administered by OFAC, the CACR is complicated and violations can occur if one is not careful. If you are seeking to travel to Cuba make sure to consult with an attorney who is knowledgable about the CACR and experienced in dealing with OFAC.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.