Activies with Cuba
In December 2014, the Obama Administration announced a new policy aimed at supporting independent economic activity in Cuba and improving communications by and living conditions for the Cuban people. Since then, both OFAC and the Department of Commerce’s Bureau of Industry and Security (BIS) have implemented several regulatory changes to carry out the new policy. Even with these significant recent changes, the comprehensive sanctions and embargo against Cuba remain in effect, which means that there are still travel and export restrictions with regard to Cuba.
Is my travel allowable?
Much of UF’s official travel and work in Cuba likely will be permissible without a specific export license, as long as it qualifies for certain general licenses and license exceptions. In particular, OFAC has authorized travel to Cuba under general licenses for the following 12 purposes:
- Family visits;
- Official business of the U.S. government, foreign governments, and certain intergovernmental organizations;
- Journalistic activity;
- Professional research and professional meetings;
- Educational activities;
- Religious activities;
- Public performances, clinics, workshops, athletic and other competitions, and exhibitions;
- Support for the Cuban people;
- Humanitarian projects;
- Activities of private foundations or research or educational institutes;
- Exportation, importation, or transmission of information or informational materials; and
- Certain authorized export transactions.
Keep in mind that tourist travel to Cuba still is not allowed without a specific license. Further, when traveling pursuant to one of the general licenses above, you must ensure that your schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule of authorized activities and you must keep records that demonstrate your full-time schedule of authorized activities for 5 years following your trip.
To determine whether your planned travel and activities will qualify for one of the 12 general licenses, review the OFAC FAQs, contact the Division of Research Compliance for guidance, and register your travel with the UF International Center.
What can I bring to Cuba?
In addition to making sure your travel is authorized, you need to be sure that you have the proper authorization to export any items or information you plan to bring with you to Cuba. There are several license exceptions available that likely will cover most items you need to bring with you for your UF business. For example, the Support for the Cuban People (SCP) license exception allows travelers to bring many items to Cuba for their use in scientific, archeological, cultural, ecological, educational, historic preservation, or sporting activities, or professional meetings or research. There are various requirements needed to qualify for the SCP or other license exceptions to Cuba. Before you bring anything other than a standard computer, cell phone, and personal items (e.g., clothes, toiletries) on your trip, review the BIS FAQs and contact the Division of Research Compliance for approval.