New OFAC Regulations in Our Context
After months of aggressive rhetoric by the Trump Administration, on June 4, 2019, the US Treasury department finally made changes to the OFAC regulations and restricted some of the travel previously enjoyed under general license by the Obama administration.
We read articles and watched videos that mention “educational travel restricted” leading to a lot of uncertainty and hesitation. To this day, we still receive a fair amount of questions and concerns about how the changes impact us and our ability to continue developing the meaningful partnerships or beginning new ones.
While the removal of the general license category of “People-to-People” has had a terrible effect on the Cuban private sector in general, the changes have little to no impact on the opportunities for the development of academic programs and attendance of conferences we have been supporting and you have been engaged since the normalization began in 2014.
Educational Travel Is A Go
As of June 4, the category of people-to-people travel was removed but other types of educational travel including for-credit programs is still allowed under the general license category now known as “Educational Activities.” This means that the semester-long program that you have been working on can still happen. The short-term program that your college or university offers for credit is still allowed. The professors that are co-leading the course that is being offered for credit can still travel to Cuba and teach the course. Are you not done developing the course yet? You can travel under the general license to plan it.
Professional Research and Professional Meetings – YES!
The OFAC general license for professional research and professional meetings in Cuba still remains. You can still participate or attend conferences as long as it relates to your professional background and you maintain a full time schedule of related events and exchanges. So as educators, you can participate and/or present at the academic conferences you have been attending previously or new ones, if you were unsure. You can still visit the universities to meet with your colleagues to plan for future programs. This has not changed.
The other nine general license categories also remain unchanged, including family-related, religious reasons or in support for the Cuban People. University programs for development purposes or alumni relations are still possible if done properly.
No matter what type of general license category you select, just make sure that you are not spending money directly on companies and locales that are part of the list of Restricted Entities and Sub-entities associated with Cuba. Sorry, most resorts in Varadero will still have to wait.
To read the entire the code of federal regulations as it relates to the Cuban Assets Control Regulations click here or better yet, forward it to your risk assessment office as you pack your bags and set up your out-of-office messages.
If you have any other questions or concerns for us, feel free to reach out to us directly at CubaPrograms@CivitasGES.com.
For more information on how to participate in Cuba TIES, please visit https://www.CivitasGES.com/cuba-ties-v.
