On Friday the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated its Comprehensive Guidelines for License Applications to Engage in Travel-Related Transactions Involving Cuba (Guidelines). According to the Guidelines, OFAC will provide specific license authorization for travel related transactions directly incident to educational activities involving non-commercial academic research in Cuba, participation in a formal course of study at a Cuban academic institution, or teaching at a Cuban academic institution.

Specific license authorization for these types of travel related transactions is not needed if traveling under the auspices of an accredited U.S. graduate or undergraduate degree granting institution, as such transactions are already authorized pursuant to a general license found at 31 C.F.R. 515.565. Those who do require specific license authorization, however, should make sure to include the following information in their license application:

1. Personal Identifying Information: Such information includes the names of the Applicants and their contact information.

2. Travel Identifying Information: State the category of activities to be engaged in whether it be noncommercial academic research in Cuba, participation in a formal course of study at a Cuban academic institution, or teaching at a Cuban academic institution.

3. Description of Educational Activities: Provide details about the particular type of activities such as the proposed dates and time of the trip, as well as specific activities to be undertaken.

4. Supporting Information: Provide supporting documentation such as brochures, and/or a letter from an appropriate representative of your academic institution.

5. Information for Extensions or Renewals: If you are seeking to extend or new a license for travel to Cuba under this category, provide an explanation of why an extension or renewal is necessary, a detailed report of all the activities previously undertaken pursuant to the license, and a complete copy of the previously issued license and/or amendments.

6. Signature: As always a signature is needed for an OFAC submission.

Travel to Cuba has relaxed significantly over the past several years, however, there is still a need to obtain OFAC specific license authorization for travel to Cuba in many scenarios. For more information contact an attorney specialized in OFAC and Cuba travel in order to determine whether or not you can travel to Cuba and under what circumstances.

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