More detailed information about the Cuban Sanctions is located on OFAC’s website, including a useful Cuban FAQs document. Additionally, the State Department has issued a Travel Warning for Cuba, located here.
There are currently 12 general licenses under CACR. The following are most relevant to the academic community. It is important to note that even if your travel and transactions are permitted under these general licenses, you are still prohibited from doing business with specific entities tied to the Cuban military, including hotels, stores, and tourist agencies. These entities are listed on the U.S. State Department's Restricted Cuban Entities list. The most recent List of Restricted Entities and Subentities Associated with Cuba and the Prohibited Accomadations List can be found on the State Department's website.
Transactions related to information and informational materials 31 CFR § 515.545 This section authorizes certain activities relating to the creation, editing, and distribution of informational materials, including printed publications, films, music, and other media.
Professional research and professional meetings in Cuba 31 CFR § 515.564 This section permits travel to Cuba (and related transactions) for the purpose of conducting full-time, bona fide research that relate to the traveler’s professional area of expertise (including graduate-level studies). Additionally, this section authorizes travel to Cuba (and related transactions) for attendance at, or organization of, professional meetings or conferences that directly relate to the traveler's professional background or area of expertise. In both cases, the traveler’s schedule of activities can not include free time or recreation in excess of that consistent with a full-time schedule of professional research.
Educational activities 31 CFR § 515.565
This section authorizes U.S. universities, their students and full-time permanent faculty and staff, to engage in travel to/transactions with Cuba related to certain educational activities, which include but are not limited to the following (if travelling individually, a letter is required from Brown). If your proposed activity is not covered by any of the scenarios below, please contact the University Export Control Officer to determine whether the activity is covered under another general license.
- Participation in a structured educational program in Cuba as part of a course offered at the U.S. institution, provided the program includes a full term, and in no instance includes fewer than 10 weeks, of study in Cuba;
- Noncommercial academic research in Cuba specifically related to Cuba and for the purpose of obtaining a graduate 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 undergraduate or graduate degree at the U.S. institution and provided that the course of study is no shorter than 10 weeks in duration;
- Teaching at a Cuban academic institution by an individual regularly employed in a teaching capacity at the U.S. institution, provided the teaching activities are related to an academic program at the Cuban institution and provided that the duration of the teaching will be no shorter than 10 weeks;
- Sponsorship of a Cuban scholar to teach or engage in other scholarly activity at the sponsoring U.S. academic institution;
- Participation in a structured educational program in Cuba as part of a course offered for credit by a U.S. graduate or undergraduate degree-granting academic institution that is sponsoring the program
- Sponsorship or co-sponsorship of non-commercial 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 and joint non-commercial academic research projects with universities or academic institutions in Cuba; or
- 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.