Cuba Sanctions and Travel

On June 9, 2022, the Office of Foreign Assets Control (OFAC) amended the regulations concerning categories of authorized travel to Cuba and imposed additional conditions on authorized travel. Specifically:

• The General License authorizing Professional Meetings has been reinstated. Any travel related to attending a conference or professional meeting in Cuba no longer requires a specific license from OFAC. This General License does not authorize:
  • Lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge at any property identified on the U.S. State Department’s Cuba Prohibited Accommodations List (CPA)
  • Direct financial transactions with entities on the Cuba Restricted List: https://www.state.gov/cuba-sanctions/cuba-restricted-list/

Complying with the terms of General License authorizations may be challenging. Please consult the Office of Export Compliance well in advance of travel.

In addition, Penn faculty, staff, and students traveling to Cuba under University of Pennsylvania sponsorship must carry an appropriate authorization letter printed on University letterhead and signed by the designated representative for Penn. Please contact expctrl@lists.upenn.edu or 215-573-8817 for assistance in obtaining the required letter.

We will update this guidance as new information becomes available. Please contact the Office or Research Services or the Global Support Services Office for more information and assistance.

The following activities may be sponsored by Penn and conducted under a General License available to accredited U.S. undergraduate and graduate degree granting academic institutions (please note that an entire group does not qualify for a general license merely because some members of the group qualify individually):

• Educational travel program in Cuba as part of a course offered for credit at Penn
• Student travel to Cuba for non-commercial academic research specifically related to Cuba and for the purposes of obtaining a graduate degree at Penn
  • Note that most undergraduate research does not fall under a General License. Please contact expctrl@lists.upenn.edu to see if your travel is eligible
• Participation in a formal course of study at a Cuban academic institution where the completed coursework will be accepted for credit toward the student’s degree by Penn (Undergraduate students should contact Penn Abroad for program details)
• Penn faculty travel to Cuba to teach at a Cuban academic institution related to an academic program at the Cuban institution, provided that the faculty member remains employed by Penn for the travel period
• Travel to Cuba by Penn faculty and staff that may be required for organization of and preparation for any of these activities may also be sponsored by Penn
• Certain other Educational Activities may be authorized under this General License. Please contact expctrl@lists.upenn.edu for questions concerning other types of Educational Activities that may be eligible.

Penn faculty or graduate students wishing to travel to Cuba to engage in research activities may be able to do so under a General License. In order for such activities to meet the requirements for this general license, the following conditions must be met:

• The research directly relates to the traveler’s profession, professional background, or area of expertise, including area of graduate-level, full-time study;
• Is not in pursuit of a hobby, tourism, recreational travel, or research for personal satisfaction only;
• Comprise a full-time work schedule in Cuba; and
• The traveler’s schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule of professional research.

These General Licenses do not authorize lodging or paying for lodging at any property identified on the U.S. State Department’s Cuba Prohibited Accommodations List (CPA), or engaging in direct financial transactions with entities on the Cuba Restricted List: https://www.state.gov/cuba-sanctions/cuba-restricted-list/.

• If the conference or meeting is scheduled to take place at a property on this list, you must find alternative accommodations. This applies even if a third party offers to pay for your accommodations.

According to OFAC regulations, Penn faculty, staff, and students traveling to Cuba under University of Pennsylvania sponsorship must carry an appropriate authorization letter printed on University letterhead and signed by the designated representative for Penn. Please contact expctrl@lists.upenn.edu or 215-573-8817 for assistance in obtaining the required letter.

• Please contact Global Support Services for guidance on arranging Penn-related Cuba travel.
• There is no per diem limitation on authorized travelers’ spending in Cuba. Normal limits on duty and tax exemptions for merchandise imported as accompanied baggage for personal use will apply.
  • No Cuban-origin alcohol and tobacco products may be brought back to the United States, even if for personal use.
• Certain Penn-owned equipment, including laptop computers, digital cameras, or cell phones may be taken to Cuba under a license exception under appropriate circumstances; however, there are additional recordkeeping and filing requirements associated with taking Penn-owned items to Cuba. Items should be accompanied by a Penn letter of ownership, need to be kept under the control of the traveler while in Cuba, and must be brought back to the United States. If traveling with export-controlled technology or material, a specific license may be required. It may take up to 2 months to obtain a license. Please contact the Export Compliance Office (expctrl@lists.upenn.edu) if you need additional information or to obtain a license to carry Penn-owned equipment to Cuba.
• Items that are personally owned by the traveler may be taken to Cuba as long as they do not contain export-controlled technology.
• To comply with U.S. sanctions, DUO, Penn’s multi-factor authentication tool, blocks authentications from users whose IP address originates in certain locations, including Cuba. DUO will not function and may not be used in Cuba. Due to regulatory restrictions, there is currently no recommended alternatives to access PennKey-protected sites from these regions. Travelers should be aware that IT resources will be limited and discuss with their School/Department/Center to determine what accommodations can be made ahead of time.
• All records of transactions related to Cuba travel must be retained for 5 years after the completion of the travel.

Additional Considerations

The above information is to ensure compliance with the U.S. Cuban Assets Control Regulations administered by OFAC. In addition to meeting these requirements, travelers to Cuba must meet all applicable visa requirements imposed by the Cuban Government. Generally, educational travel must be approved or arranged through an agency authorized by the Cuban Government or sponsored by a Cuban institution, such as the University of Havana. Professional research must similarly be sponsored by a Cuban institution. It is important to recognize that sponsoring organizations in Cuba will have their own processes for approval, and that it may take several weeks or months for a proposed activity to be approved by the sponsor.