Cuba: Travel Rules Changed & Unchanged

For starters, it is important to note that payments by US persons to Cubans and Cuban companies for expenses relating to tourist travel are still prohibited under the Treasury Department’s Cuban Assets Control Regulations (the “CACR”); and the Department’s existing restrictions/authorizations relating to travel for such things as family visits, journalistic/professional/religious activities, public performances/competitions and the like remain the hodge-podge that is road-mapped at 31 CFR 515.600.

That said, however, the Department’s Office of Foreign Assets Control (“OFAC”) has adopted a new general license that authorizes payments which are “directly incident to market research, commercial marketing, sales negotiation, accompanied delivery, or servicing of exports that are consistent with certain other licensing policies,” but only if the traveler’s schedule of activities does not include free time or recreation in excess of that consistent with a fulltime schedule” (i.e., tourist-type travel).

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