Cuba Travel Policy

The U.S. Government broadly regulates and restricts transactions involving Cuba under the Cuban Assets Control Regulations 31 CFR Part 515 (CACR) The regulations prohibit persons subject to U.S. jurisdiction from engaging in transactions in which with Cuba or Cuban national has direct or indirect interest, including transactions related to travel. This prohibition includes travel-related transactions that are not authorized under a general or specific license. A general license authorizes the activity or transaction within the regulations if all conditions are met. A specific license is issued on a case-by-case basis by the Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury. See more below under "Activity Restrictions."

The CACR is subject to change, and the detail below was updated under the guidance of the Export Control Office July 29, 2022.

Due to the restricted nature of travel to Cuba, Emory-sponsored travel requires advanced review and approval. This review and approval is specific to travel to Cuba and is in addition to any other department, school, or university travel approvals that may be required.

If you are planning travel to Cuba, please contact Global Services and follow the procedures outlined below. 

Procedures for Emory Travel to Cuba

1) Contact Global Services to facilitate Export Control Office and Office of Insurance Services review:
As soon as you learn of potential travel to Cuba, send the following information to 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

Global Services will then work with the Export Control Office to determine if a specific license is needed or if the travel can take place under a general license. Specific licenses can take several months to obtain and are not always granted. 

Global Services will contact Emory's Office of Insurance Services to request insurance coverage and documentation for your travel to Cuba. Even if your trip is permitted under a general or specific license, Emory's Office of Insurance Services must be notified ahead of your travel so that coverage can be secured, as appropriate.

Global Services will work with Office of Insurance Services to 1) request workers compensation and general liability coverage for your time in Cuba, and 2) obtain documentation of your International SOS 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

2) Request travel permission as required by your department, school, or by the University. 

3) Review the "Guidance for Travelers to Cuba" below to understand traveler responsibilities, restrictions, requirements. 

4) Contact Alma Reynal Quintanilla in Global Safety and Security, for a 30-minute briefing on safety, security, and an overview of the resources available to Emory travelers. 

5) 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.

6) Make your travel arrangements. Emory's travel vendors can book travel to Cuba. If travelers wish to book through CTM, they are advised to book through a CTM agent rather than the online booking portal when making travel arrangements for Cuba. See details on Emory’s travel vendors here, and please contact Emory Travel if you have any questions about booking travel to Cuba with an Emory agency.

7) Register your flight, hotel, and any other internal transit with International SOS.

Activity Restrictions

Activities Prohibited Without Specific U.S. Government Authorization

Any activity that is not described below as being authorized under a general license also requires a specific license from OFAC.

Please note specific licenses can take months to process, so it is important to contact the Export Control Office as soon as possible. Licenses are not guaranteed.

Activities Authorized Under General Licenses

Some activities are authorized under a general license in the CACR, meaning that there is no need to apply for a specific license. These activities include:

Professional Research (see §515.564(a)(1)): Travel-related transactions listed below and other additional transactions directly incidental to professional research are authorized provided that:

  1. The purpose of the research directly relates to the traveler's profession, professional background, or area of expertise, including area of graduate-level full-time study; and
  2. 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.

Professional Meetings in Cuba (see §515.564(a)(2)): Travel-related transactions listed below and other additional transactions directly incident to attendance at, or organization of, professional meetings or conferences in Cuba are authorized, provided that:

  1. For a traveler attending a professional meeting or conference, the purpose of the meeting or conference directly relates to the traveler's profession, professional background, or area of expertise, including area of graduate-level full-time study;
  2. (ii) For a traveler organizing a professional meeting or conference on behalf of an entity, either the traveler's profession must be related to the organization of professional meetings or conferences or the traveler must be an employee or contractor of an entity that is organizing the professional meeting or conference; and
  3. (iii) The traveler's schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule of attendance at, or organization of, professional meetings or conferences.

NOTE: An entire group does not qualify for the general license in paragraph (a) of §515.564 merely because some members of the group qualify individually.

Educational Activities (see §515.565): Travel-related transactions listed below and other additional transactions directly incidental to educational activities specified in §515.565(a)(1) and §515.565(a)(2) are authorized. Educational activities most relevant to Emory include:

  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 an undergraduate or graduate degree.
  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 an undergraduate or graduate degree.
  4. Teaching at a Cuban academic institution related to an academic program at the Cuban institution, provided the individual is a regular employee of Emory.
  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.
  8. Provision of internet-based courses, including distance learning and Massive Open Online Courses, to Cuban nationals, wherever located, provided that the course content is at the undergraduate level or below.

The Educational Activities 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.

Note: For those activities above with a 10-week minimum stipulation, travel may still be authorized if:

  • The Emory employee, Emory paid consultant, or Emory agent is traveling individually; or
  • A group of travelers is accompanied by an Emory Representative (e.g., Emory employee, Emory paid consultant, Emory agent) who is subject to U.S. jurisdiction.

Travelers to Cuba 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 accompanied by another Emory Representative with a letter from Emory, provided that the individual traveler is covered by that letter. This letter will be provided to you by the Export Control Office during the trip approval process.

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

Guidance for Travelers to Cuba

Travel-related Transactions Authorized Under General Licenses

See § 515.560(c)

  • Transportation to, from, and within Cuba; Cuban visas. All transportation-related transactions ordinarily incident to travel to, from, and within Cuba, including the acquisition of Cuban visas, are authorized.
  • Living expenses in Cuba. All transactions ordinarily incident to travel within Cuba, including payment of living expenses and the acquisition in Cuba of goods for personal consumption there, are authorized.
  • Importation of Cuban merchandise. The purchase or other acquisition in Cuba and importation as accompanied baggage into the United States of merchandise is authorized, provided that the merchandise is imported for personal use only. This does NOT authorize importation of Cuban-origin alcohol and tobacco products.
  • Importation, export and transmission of information and informational materials such as publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, news wire feeds, and other information and informational articles, as defined in 31 C.F.R. §515.332, that are fully created and in existence at the date of the transaction are generally exempt from the prohibitions and regulations. It should be noted that the exemption does not permit substantive or artistic alteration or enhancement of information or informational materials, or to the provision of marketing and business consulting services.
  • Credit and debit cards. All transactions incident to the processing and payment of credit and debit cards involving authorized transactions are also authorized. Travelers should check with their financial institution before traveling to Cuba to determine whether the institution has established the necessary mechanisms for its credit or debit cards to be used in Cuba.

Limitations on General Licenses by the Cuba Restricted List: Prohibited Hotels, Businesses, Entities

The U.S. Department of State maintains a list of Cuban entities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel. This list includes several hotels and accommodations facilities in major Cuban cities.

Emory travelers are prohibited from conducting any transactions with parties on the list, including lodging at any listed lodging facility. U.S. persons are prohibited from engaging in a direct financial transaction with entities and subentities identified on the list, referred to as the Cuba Restricted List.

Travel with University Laptop and Equipment

Generally, Emory travelers traveling under the general licenses outlined above can rely on an export control license exception called Support for the Cuban People (SCP) to travel with their Emory-issued laptop. This exception requires an electronic filing with U.S. Customs called Electronic Export Information (EEI). The same license exception may be available for other items. Please notify Global Services of all items that you plan to take on your trip. The Export Control Office will assist with evaluating license exceptions and submitting any required filings.

Record-keeping 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 Global Services.