Cuba travel policy

Last Updated: February 1, 2018

The U.S. government's rules regarding travel to Cuba continue to evolve. On November 9, 2017, important amendments to the Cuban Assets Control Regulations were announced that pertain to travel for educational activities. The prohibition on travel to Cuba for the purpose of tourism remains in place. 

The U.S. Department of Treasury allows certain professional and educational travel to, and types of transactions in and with, Cuba under a "general license." Emory-sponsored travel to Cuba must be reviewed to determine if it is permitted under this general license. If it is not, a "specific license," which requires approval from the U.S. Government, will be needed. Applying for a specific license typically requires outside legal assistance, the cost of which would be the responsibility of the department or program proposing the travel.

To ensure you are able to obtain any additional licenses needed if the general license does not extend to your trip, please begin the process of arranging travel to Cuba no later than three to four months in advance of your planned trip. 

If you have questions, or are considering traveling to Cuba on Emory business that does not fall into the categories above, please contact Chris Rapalje.

Educational activities | Professional research and meetings | Restricted Parties | Procedures | Recordkeeping | Resources


 

Travel for Certain Educational Activities

Emory faculty, staff, and students may travel to Cuba under the general license for certain "Educational Activities" (see more detail on these activities under 31 CFR 515.565).

Note that travel for allowable educational activities, with the exception of item 2 below regarding academic research, must be no shorter than 10 weeks in duration unless those traveling are accompanied by an Emory representative (employee, paid consultant, agent) who is subject to U.S. jurisdiction (“Emory Representative”). Also, in most circumstances, travelers must carry a letter from Emory that states their travel meets these requirements. Letters for faculty or staff travelers should state their status as full-time regular Emory employees unless they are otherwise accompanied by another University representative with a letter from Emory. This letter will be provided to you by the Office of Global Strategy and Initiatives during the trip approval process. 

Educational activities most relevant to Emory are listed below:

  1. Participation in a structured educational program in Cuba as part of a for-credit course sponsored by Emory.
  2. Noncommercial academic research specifically related to Cuba for the purpose of obtaining a graduate degree, or an undergraduate degree if the undergraduate student is accompanied by an Emory Representative.
  3. Participation in a formal course of study at a Cuban academic institution, provided the course of study will be accepted by Emory for credit toward a degree.
  4. Teaching at a Cuban academic institution related to an academic program at the Cuban institution, provided the individual is a full-time regular employee of Emory or is accompanied by an Emory Representative.
  5. Sponsorship or co-sponsorship of noncommercial academic seminars, conferences, symposia, and workshops related to Cuba or global issues involving Cuba. Emory faculty, staff, and students may also attend such events.
  6. Establishment of academic exchanges and joint non-commercial academic research projects with Cuban universities or academic institutions.
  7. The organization of, and preparation for, activities described above by Emory faculty and staff.

The general license also allows Emory to sponsor Cuban scholars to teach or engage in other scholarly activities at Emory and to pay the scholar a stipend or salary to do so.

Travel for Allowable Professional Research and Meetings

In addition, travel to Cuba is permitted under the general license for professional research and professional meetings (31 CFR 515.564) provided that the following conditions apply:

  1. The purpose of the research or meeting directly relates to the traveler's profession, professional background, or area of expertise, including area of full-time graduate study.
  2. The purpose of meetings and conferences attended is not the promotion of tourism in Cuba.
  3. The traveler doesn't engage in recreational or tourist travel, travel in pursuit of a hobby, or research for personal satisfaction only.
  4. 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 or a full-time schedule of professional meeting and conference attendance.

For full details, please review the U.S. Department of Treasury's information on the Cuba Sanctions program.

Restricted Parties

Emory travelers are prohibited from conducting any transactions with entities on the State Department Restricted Entities and Subentities Associated with Cuba list. These restricted parties include specific hotels, marinas, stores, and other entities.

If you have questions, or are considering traveling to Cuba on Emory business that does not fall into the categories above, please contact Chris Rapalje.

Take Note: Emory General Liability Insurance, Workers' Compensation, and ISOS Travel Assistance Coverage

Even if your trip is permitted under the general license, Emory's Office of Quality and Risk (OQR) must be notified ahead of your travel so that workers' compensation and general liability coverage can be secured, as appropriate. In addition, Emory University provides ISOS coverage for all students and employees traveling on behalf of Emory or on an Emory-sponsored program. OQR can provide ISOS Travel Assistance coverage documentation that may be requested by Cuban authorities upon entry. See Procedures, below, for additional detail.

Procedures for Emory Travel to Cuba

  1. As soon as you learn of potential travel to Cuba, send the following information to Chris Rapalje in Global Services:
    • The reason for your trip
    • Expected activities while in Cuba, including a detailed itinerary and potential or confirmed accommodations and engagement partners 
    • Anticipated travel dates
    • Any Emory-owned items or equipment (e.g., laptops) you plan to take with you
  2. Global Services will then work with Emory's Office of the General Counsel and Office of Compliance to determine if a specific license is needed or if the travel can take place under the general license. While Emory can typically make this determination, outside legal guidance is needed in some cases and is always required for specific license applications. The costs for this guidance must be covered by the traveler's department. Specific licenses can take over 45 days to obtain and are not always granted.
  3. Global Services will work with the Office of Quality and Risk to:
    • Request workers compensation and general liability coverage for your time in Cuba and
    • Obtain documentation of your ISOS coverage, which may be requested by Cuban authorities upon entry. This step takes at least 10 days and requires the following information:
      • Your full name as it appears on your passport
      • Your finalized travel dates
  4. Review the U.S. State Department's information on visa, entry, and exit requirements for Cuba. As noted there, travelers should contact the Cuban Embassy in Washington to determine the appropriate type of visa for their travel.
  5. Make your travel arrangements. Emory's preferred travel agencies do not currently book travel to Cuba. When you submit an expense reimbursement request for your trip, indicate that you did not use a preferred agency due to this limitation.
  6. Register your travel with ISOS through the "My Trips" link on Emory's ISOS website. This step is required for any international travel not booked through one of Emory's preferred travel agencies.

Recordkeeping Requirements

U.S. regulations require travelers to Cuba to retain detailed documentation of their itinerary in Cuba. The itinerary must reflect a full-time schedule of activities that directly pertains to the permitted trip purpose. For example, those traveling to participate in a permitted educational program must have an itinerary that documents their full-time engagement in such a program.

Travelers to Cuba must also maintain records of all of their travel-related transactions, including those:

  • Related to transportation and ordinary travel expenses (e.g., lodging, living expenses, meals and other items for personal consumption).
  • Related to the purchase of Cuban goods to be brought bring back to the U.S.
  • Incident to the processing and payment of credit cards, debit cards, stored value cards, traveler’s checks, and similar mechanisms (as well as the opening and closing of any bank accounts, if relevant).

Travelers should retain their itinerary and records for five years.

Resources

If you have questions about this policy or other matters related to travel to Cuba, please contact Chris Rapalje.