Professional and Educational Travel and Activities Involving Cuba
Trips to Cuba are subject to restrictions in the Cuban Assets Control Regulations (CACR) administered by the Office of Foreign Assets Control (OFAC), and must be approved by the university's Export Controls Officer (ECO). The ECO will authorize travel to Cuba and related activities in reliance on a general license in the CACR in the following situations.
Professional Research, Meetings, and Conferences
Professionals are authorized to travel to Cuba to conduct research and attend meetings and conferences, provided:
- The research, meeting, or conference directly relates to the traveler’s profession or area of expertise, including full-time graduate study
- The purpose of the trip is not tourism, recreation, or the pursuit of a hobby or personal interest
- The traveler’s schedule does not include free time in excess of that consistent with a full-time research effort or attendance at professional events
Structured Educational Programs
University faculty, staff, and students are authorized to travel to Cuba to participate in a structured educational program as part of a course offered for credit by the University.
Academic Research
University students are authorized to travel to Cuba to conduct noncommercial academic research that is both:
- Specifically related to Cuba
- Being conducted in pursuit of an undergraduate or graduate degree.
Study in Cuba
University students are authorized to travel to Cuba to participate in a formal course of study at a Cuban academic institution provided the course of study will be accepted for credit toward the student’s graduate or undergraduate degree from the University.
Teaching in Cuba
Faculty members regularly employed in a teaching capacity by the University are authorized to travel to Cuba to teach in certain programs at a Cuban academic institution.
Sponsoring Events in Cuba
The University may sponsor or cosponsor noncommercial academic seminars, conferences, and workshops related to Cuba or global issues involving Cuba. Faculty, staff, and students are authorized to travel to Cuba to participate in such events.
Academic Exchanges and Research Projects
Activities relating to the creation and operation of academic exchanges and research projects are authorized.
Standardized Testing
The University may provide standardized testing services—including entrance and professional exams—to Cuban persons.
Online Courses
Online undergraduate teaching, including Massive Open Online Courses, may be made available to students in Cuba. Online graduate-level courses are not authorized.
Organizing Trips
Faculty and staff may travel to Cuba to organize and prepare for the educational activities described above.
Specific License
For travel and other activities involving Cuba that do not qualify for a general license, the ECO will work with travelers in applying for a specific license from OFAC. Whether a specific license will be approved depends on the current state of US Government policy, which may change over time, and which the ECO can explain. One thing that rarely changes, however, is the length of time it takes to obtain a specific license. This process can range from one to three months. Accordingly, travelers should consult the ECO as early as possible.
Off-limits Businesses
Even when travel to Cuba is authorized by a general or specific license, US law prohibits personnel from patronizing hotels, restaurants, and other organizations specified on the Cuba Restricted List and the Cuba Prohibited Accommodations List.
Duo Usage
Duo multi-factor authentication will not function and may not be used in Cuba (among other sanctioned countries). Travelers must coordinate with the University’s Technology Help team to temporarily suspend Duo in advance of trips to Cuba. This suspension might impact the availability of certain University IT services, such as VPN connectivity and restricted-access websites and applications.
Visiting Cuban Scholars
In certain cases, Cuban scholars may teach or engage in other academic activities at the University if sponsored by a University college or department. Before engaging a Cuban scholar, consult the ECO to discuss the requirements.
Other Resources
- OFAC Cuba Sanctions
- US Relations With Cuba, published by the US Department of State