Background
Cuba is among the group of nations with whom the US maintains comprehensive embargoes. It is in the company of countries such as Iran, North Korea, occupied areas of Ukraine, and Syria.
Many of the restrictions can be found in the Cuban Assets Control Regulations (CACR).
Sanctions against Cuba are in a state of flux. You should check early in your plans with MIT's Export Control Officer to verify that your planned activity is legal.
Export Control Considerations
See Export Administration Regulations (EAR) section 746.2 page 2 for permissible exports and "deemed exports" to Cuba. Note that a license is still required to export many kinds of items. What has changed is the U.S. Government is much more likely to approve them now for certain categories of items. The Department of the Treasury provides the most updated guidance on Cuba sanctions.
Going to Cuba for tourism purposes is not permitted by the US Government. However, the Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued a general license authorizing 12 categories of travel:
- Educational activities for schools,
- Professional research and professional meetings
- Public performances, clinics, workshops, athletic and other competitions, and exhibitions
- Religious activities
- Humanitarian projects
- Journalistic activities
- Family visits
- Official business of the U.S. government, foreign governments, and certain intergovernmental organizations
- Support for the Cuban people
- Activities in Cuba by private foundations or research or educational institutes;
- Exportation, importation, or transmission of information or informational materials
- Certain authorized export transactions including agricultural and medical products, and tools, equipment and construction supplies for private use
If you wish to engage in an activity not permitted by the 12 categories, you must apply for and obtain a license from OFAC.
Note: for several of these you are required to keep a journal of your daily activities. It is probably OK to attend a tourist type of activity on weekends when you are outside of business hours, but be sure to note this in your journal. You should keep a copy of your journal for 5 years and, in addition, you can file a copy with the MIT Export Control Officer.
You should carry with you a letter on MIT stationery stating your affiliation with MIT, purpose for travel, that you are travelling under the Cuba Assets Control Regulations (CACR 31 CFR Section 515.565 (a)(1)) and under which of the 12 permissible categories your activities fall. The letter should be signed by the traveler and his/her Department/Lab/Center head. A copy should be filed with the MIT Export Control Officer (exportcontrolhelp@mit.edu).
Travel Advice, Visas, Currency, Journal Requirements, etc.
If you meet the conditions of the general license you do not need to apply for an additional license from OFAC to travel to Cuba. See the Treasury Department's FAQs for more detail on the definitions of the terms in the 12 permitted reasons to travel to Cuba.
Making payments to Cuba, even those for which you have a license or no license is required, is still prohibitively difficult. Also, in Cuba you will not have access to ATM networks you are accustomed to in the US and Europe. Check with your financial institution before traveling to Cuba to determine whether the institution has established the mechanisms for its credit or debit cards to be used in Cuba. Likely it has not. Count on paying for everything in cash.
The Cuban government requires all citizens traveling to Cuba to obtain a Cuban visa prior to their arrival into Cuba. A Cuban visa is also known as a "tourist card.” For US Citizens this “tourist” card may also be referred to as a “visitor” card to avoid the appearance of tourism, which is not a sanctioned activity by the U.S. Government. US authorities do not seem to be concerned about Americans using the tourist card as long as they are travelling under one or more of the 12 permitted categories. The Cuban visa is valid for a single entry and allows the holder to stay in Cuba for 30 days. The Cuban visa is a two-part card. Cuban immigration officials will take one half upon arrival in Cuba, and guests will surrender the other half upon departure. Make sure to keep your Cuban visa in a safe place with you throughout your trip so you have it with you when you depart the country.
Health and Safety Considerations
The U.S. Department of State provides more information about traveling to Cuba at Travel.State.Gov.
Since you will be conducting your business entirely in cash, be aware that you will be an attractive target for personal property theft.
Review travel and safety information provided by Global Support Resources.
MIT Resources
For questions please contact MIT Export Control or International Safety & Security, Todd Holmes, 617-324-7696, tholmes@mit.edu. For guidance in planning, negotiating and implementing international projects, please contact the International Coordinating Committee (ICC) at internationalhelp@mit.edu.
Members of the MIT community can review current security and medical alerts through International SOS. Other resources for international activities are collected in Global Support Resources.