OFAC Guidelines for Educational Activities
§ 515.565(a) Educational activities.
(1) Participation in a structured educational program in Cuba as part of a course offered for credit by a U.S. graduate or undergraduate degreegranting academic institution that is sponsoring the program;
(2) Noncommercial academic research in Cuba specifically related to Cuba and for the purpose of obtaining an undergraduate or graduate degree;
(3) Participation in a formal course of study at a Cuban academic institution, provided the formal course of study in Cuba will be accepted for credit toward the student’s graduate or undergraduate degree;
(4) Teaching at a Cuban academic institution related to an academic program at the Cuban institution, provided that the individual is regularly employed by a U.S. or other non-Cuban academic institution;
(5) Sponsorship, including the payment of a stipend or salary, of a Cuban scholar to teach or engage in other scholarly activity at the
sponsoring U.S. academic institution (in addition to those transactions authorized by the general license contained in § 515.571). Such earnings may be remitted to Cuba as provided in § 515.570 or carried on the person of the Cuban scholar returning to Cuba
(6) Educational exchanges sponsored by Cuban or U.S. secondary schools involving secondary school students’ participation in a formal course of study or in a structured educational program offered by a secondary school or other academic institution and led by a teacher or other secondary school official. This includes participation by a reasonable number of adult chaperones to accompany the secondary school students to Cuba.
(7) Sponsorship or co-sponsorship of noncommercial academic seminars, conferences, and workshops related to Cuba or global issues involving Cuba and attendance at such events by faculty, staff, and students of a participating U.S. academic institution;
(8) The organization of, and preparation for, activities described in paragraphs (a)(1) through (a)(7) of this section by members of the faculty and staff of the sponsoring U.S. academic institution or secondary school; or
(9) Facilitation by an organization that is a person subject to U.S. jurisdiction, or a member of the staff of such an organization, of licensed educational activities in Cuba on behalf of U.S. academic institutions or secondary schools, provided that:
(i) The organization is directly affiliated with one or more U.S. academic institutions or secondary schools;
(ii) The organization facilitates educational activities that meet the requirements of one or more of the general licenses set forth in
§ 515.565(a)(1), (a)(2), (a)(3), and (a)(6); and
(iii) The educational activities the organization facilitates in Cuba must, by prior agreement, be accepted for credit by the affiliated U.S. academic institution or approved by the affiliated secondary school.