Travel to Cuba
Cuba General License for Educational Activity
The general license (published by the U.S. Office of Foreign Assets Control as part of the Cuban Assets Control Regulations) authorizes accredited U.S. graduate and undergraduate degree-granting academic institutions to engage in Cuba travel-related transactions incident to certain educational activities. To be eligible, faculty, staff, and students must meet the qualifications outlined in 31 CFR §515.565 Educational Activities. Full details are available on the U.S. Government Publishing Office website.
To meet the qualifications, the Cuba travel must be under the auspices of Cornell University and be related to:
- Participation in a Cornell-sponsored structured educational program in Cuba as part of a course offered for credit. The program must be a full term, and must include a minimum of 10 weeks in Cuba if the traveler is not accompanied by a Cornell employee.
- Noncommercial academic research in Cuba specifically related to Cuba and for the purpose of obtaining an undergraduate (but only when accompanied by a Cornell employee) or graduate degree. The research in Cuba must be accepted for credit towards that degree.
- 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 and provided that the course of study is no shorter than 10 weeks in duration if the traveler is not accompanied by a Cornell employee.
- Teaching at a Cuban academic institution by an individual regularly employed in a teaching capacity at Cornell University, provided the teaching activities are related to an academic program at the Cuban institution.
- Sponsorship of a Cuban scholar to teach or engage in other scholarly activity at Cornell University (in addition to those transactions authorized by the general license contained in § 515.571).
- 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.
- Sponsorship or co-sponsorship of noncommercial academic seminars, conferences, symposia, 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.
- Establishment of academic exchanges (on behalf of Cornell University) and joint non-commercial academic research projects with universities or academic institutions in Cuba.
- Provision of standardized testing services, including professional certificate examinations, university entrance examinations, and language examinations, and related preparatory services for such exams, to Cuban nationals, wherever located.
- Provision of internet-based courses, including distance-learning and Massive Open Online Courses, to Cuban nationals, wherever located, provided that the course content is at the undergraduate level or below.
- The organization of, and preparation for, activities described in the above by employees of Cornell University.
- 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 Cornell University, provided that: (1) the organization is directly affiliated with Cornell University; and (2) the organization facilitates educational activities that meet the requirements of one or more of the general licenses set forth in §515.565(a)(1)(i) through (iii), (a)(2)(i) through (iii), and (a)(2)(vi).
In addition to the above, travel to Cuba may be authorized for professional research or meetings when certain specific requirements are met.
Please note that all of the above require additional factors and considerations to meet the requirements of the license. Additional factors may include time duration minimums, required accompaniment by a Cornell University representative, and a verification and authorization letter. Please consult the Office of the Vice Provost for International Affairs prior to engaging in Cuba travel. Travelers to Cuba are also asked to contact Risk Management and Insurance at firstname.lastname@example.org for Travel Certification forms necessary for liability insurance coverage.
Authorization Letters Are Required from the Office of the Vice Provost for International Affairs
To obtain an authorization letter:
1. Send an email to the Office of the Vice Provost for International Affairs at email@example.com, with a copy to the Export Controls Office at firstname.lastname@example.org. Include the following information:
- Your full name and NetID
- Your status (faculty, staff, undergraduate student, or graduate student; full-time or part-time; and temporary or permanent)
- Dates of travel in Cuba (from [date] to [date])
- The relevant paragraph from the qualifying activities above to which your travel is related
- A brief description of your intended business in Cuba (You may send attachments.)
2. For your reference, you may want to visit the U.S. Department of the Treasury's "Resource Center" on Cuba sanctions: Guidance Regarding Travel Between the United States and Cuba.
If this travel is approved, you will receive an authorization letter from the Office of the Vice Provost for International Affairs. Carry this letter with you during your travel to Cuba, to show upon request.
If the travel is not approved, the Office of the Vice Provost for International Affairs will contact you with additional information.
Travelers should read the “Records and recordkeeping” and “Reports to be furnished on demand” requirements set forth under the OFAC Recordkeeping Requirements (31 C.F.R. §501.601 and §501.602) and General Cuba license, 31 CFR 515.565(a).
Cornell University and the individual travelers must retain records related to their travel transactions, to be available for examination upon demand for at least 5 years from the date of each transaction. The Office of the Vice Provost for International Affairs at Cornell University does not require an activity report.