President Trump Changes Cuba Travel Policies
The travel industry was concerned in particular as many cruise lines have made considerable investments to make Havanna, Cuba a stop on their Caribbean itineraries.
So. What has changed? Let’s look at the Department of Treasury’s Office of Foreign Assets Control (OFAC) FAQ for a few answers:
What is individual people-to-people travel, and how does the President’s announcement impact this travel authorization?
Individual people-to-people travel is educational travel that: (i) does not involve academic study pursuant to a degree program; and (ii) does not take place under the auspices of an organization that is subject to U.S. jurisdiction that sponsors such exchanges to promote people-to-people contact. The President instructed Treasury to issue regulations that will end individual people-to-people travel. The announced changes do not take effect until the new regulations are issued.
Will group people-to-people travel still be authorized?
Yes. 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.
How do the changes announced by the President on June 16, 2017, affect individual people-to-people travelers who have already begun making their travel arrangements (such as purchasing flights, hotels, or rental cars)?
The announced changes do not take effect until OFAC issues new regulations. Provided that the traveler has already completed at least one travel-related transaction (such as purchasing a flight or reserving accommodation) prior to the President’s announcement on June 16, 2017, all additional travel-related transactions for that trip, whether the trip occurs before or after OFAC’s new regulations are issued, would also be authorized, provided the travel-related transactions are consistent with OFAC’s regulations as of June 16, 2017.
Does the new policy affect how persons subject to U.S jurisdiction may purchase airline tickets for authorized travel to Cuba?
No. The new policy will not change how persons subject to U.S. jurisdiction traveling to Cuba pursuant to the 12 categories of authorized travel may purchase their airline tickets.
Is authorized travel by cruise ship or passenger vessel to Cuba impacted by the new Cuba policy?
Persons subject to U.S. jurisdiction will still be able to engage in authorized travel to Cuba by cruise ship or passenger vessel.
While I’m certain that we’ll hear more about all of this over the coming weeks, for now, if you’ve got something booked, you’re good as the announced changes do not take effect until the new regulations are issued. And, if you’re considering booking Cuba in the future, be certain that you understand these new restrictions completely.
To read more of the FAQ on President Trump’s Cuba Announcement, go here: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_faqs_20170616.pdf
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