Cuba Travel License
U of M Faculty
Faculty activity in Cuba may call for the use of the U of M license or a general license. Read below to help you decide which one is appropriate for you.
General Licenses for Faculty
Certain faculty academic activities can be undertaken with use of a general license (not the U of M specific license). General licenses constitute blanket authorization for those transactions set forth in the relevant general license regulation and are self-selecting and self-executing. No further permission from OFAC is required to engage in transactions covered by that general license.
Faculty invoking the general license should be prepared to declare and document that their activities fit within the following regulations. The Office of International Programs has prepared a template for a letter to be signed by the department chair, that vouches for the academic nature of the work and indicates that the faculty member is a full-time employee of the University of Minnesota. Please contact Stacey Tsantir if you would like a copy of this letter (see box for contact info).
Regulations for Use of the General License for Faculty
Text of Regulatory Provision for § 515.564,
Sanctions Program and Country Summaries
§ 515.564 Professional research and professional meetings in Cuba
(a) General license. (1) The travel-related transactions set forth in § 515.560(c) and such additional transactions that are directly incident to professional research by full-time professionals who travel to Cuba to conduct professional research in their professional areas are authorized, provided that:
(i) The research is of a noncommercial, academic nature;
(ii) The research comprises a full work schedule in Cuba;
(iii) The research has a substantial likelihood of public dissemination; and
(iv) The research does not fall within the categories of activities described in paragraph (c), (d), or (e) of this section.
(c) Categories of activities that do not qualify for the general license in paragraph (a) of this section and for which the specific licenses described in paragraph (b) of this section will not be issued include recreational travel; tourist travel; travel in pursuit of a hobby; research for personal satisfaction only; and any travel for an authorized professional research purpose if the schedule of activities includes free time, travel, or recreation in excess of that consistent with a full work schedule of professional research or attendance at professional meetings or conferences.
(d) An entire group does not qualify for the general license in paragraph (a) of this section and will not be issued a specific license under paragraph (b) of this section merely because some members of the group could qualify individually for such licenses.
(e) A person will not qualify as engaging in professional research merely because that person is a professional who plans to travel to Cuba.
(2) The travel-related transactions set forth in § 515.560(c) and such additional transactions as are directly incident to travel to Cuba by full-time professionals to attend professional meetings or conferences in Cuba organized by an international professional organization, institution, or association that regularly sponsors meetings or conferences in other countries are authorized, provided that:
(i) The international professional organization, institution, or association is not headquartered in the United States unless that organization, institution, or association has been specifically licensed to sponsor the meeting in Cuba;
(ii) The purpose of the meeting or conference is not the promotion of tourism in Cuba or other commercial activities involving Cuba that are inconsistent with this part; and
(iii) The meeting or conference is not intended primarily for the purpose of fostering production of any biotechnological products.
Use of the U of M-Specific License for Faculty and Staff
Full-time faculty and staff in the following categories are eligible to apply to use the U of M license to travel to Cuba:
- Persons regularly employed in a teaching capacity at a licensed college or university who plan to teach part or all of an academic program at a Cuban academic institution for a minimum of 10 weeks
- Full-time employees of a licensed institution organizing or preparing for educational activities in Cuba.
U of M faculty and staff requesting travel authorization in one of the above categories should submit a letter to Stacey Tsantir (see box for contact info) indicating the nature of their request, the dates of the proposed travel, proof of international health insurance and substantiating documentation as applicable.