As you’re perusing the Internet trying plan for a summer vacation, you may consider the home sharing service Airbnb. And as of April of this year, Cuba travelers can consider the option as well. With the recent thaw in diplomatic relations, the Office of Foreign Assets Control (OFAC) has made several changes to their Cuba sanctions program. Chief amongst them is the release of general licenses including those related to travel. Most probably in accordance with 31 CFR § 515.572, Airbnb and other U.S. persons subject to U.S. jurisdiction are generally licensed to provide ‘travel related services in connection with travel-related transactions involving Cuba’.

Airbnb, which has previously proven itself wary of OFAC regulations, has taken advantage of the license albeit cautiously. In rolling out their Cuba operations, the online service reportedly sought a great deal of guidance from OFAC and began with only a thousand listings in April of this year before progressively adding more.

Yet the service is not without caveat. Before booking a beach-front property for $35/night, keep in mind that travelers must still fall within one of the 12 categories of authorized travel. Additionally, under § 515.572(b)’s recording provision, Airbnb will be required to keep a record of each users certification of lawful travel for five years.

So does Airbnb’s entry into Cuba mean that we will be seeing more promotions from online travel agencies for resorts in Havana? Unlikely. The island government still holds a very tight grip on the country’s real estate market and hotels and resorts in Cuba are all either owned or associated with the Cuban government. This association with the government would render such entities as specially designated nationals under Section 515.306(3) thereby making transactions with them a violation of U.S. law 31 CFR 515.201.

But unlike other travel sites, Airbnb’s unique approach to travel whereby it works with individuals to rent out privately held properties, has allowed it to bypass section 515.306 to penetrate the market.

The change in U.S. law as well as the November 2011 Cuban law that permits ownership of private property has paved the way for Airbnb. Should further reform in Cuban real estate laws allow the privatization of hotels, in the coming years, a new market may open to online travel agencies as well.