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Friday
Jun232017

OFAC issues new FAQs for Cuba sanctions

The Treasury Department's Office of Foreign Assets Control published Frequently Asked Questions on President Trump’s Cuba announcement.

The biggest change will be new regulations to end so-called individual people-to-people travel. Group people-to-people travel will still be authorized.

That means travel to Cuba will have to be under the auspices of an organization that's subject to U.S. jurisdiction and has an educational purpose.

Here's how OFAC defines group people-to-people travel in the Cuba regulations:

Group people-to-people travel is educational travel not involving academic study pursuant to a degree program that takes place under the auspices of an organization that is subject to U.S. jurisdiction that sponsors such exchanges to promote people-to-people contact. Travelers utilizing this travel authorization must maintain a full-time schedule of educational exchange activities that are intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities, and that will result in meaningful interaction between the traveler and individuals in Cuba. An employee, consultant, or agent of the group must accompany each group to ensure that each traveler maintains a full-time schedule of educational exchange activities.

OFAC expects to issue amendments to the Cuba sanctions "in the coming months."

The changes announced a week ago don't take effect until the new regulations are issued, OFAC said.

The new policy won't change how persons subject to U.S. jurisdiction traveling to Cuba can buy their airline tickets. And authorized travel to Cuba by cruise ship is still allowed.

"But finding accommodations on the island will become more difficult," according to Travel Weekly.

The new directive "bans most business transactions with the Cuban military, which owns the lion's share of Cuba's tourism infrastructure, including hotels," Travel Weekly said.

More guidance will accompany the new regulations, OFAC said.

OFAC's June 16 FAQs about the Cuba sanctions are here (pdf).

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Richard L. Cassin is the publisher and editor of the FCPA Blog.