Decision tool · 12 OFAC categories · CACR §515.560–.578

Can I Legally Travel to Cuba?

Three quick questions to find out whether your trip is authorised, which OFAC category covers it, and what records you need to keep.

Step 3 of 3 · Passport: U.S. citizen / green-card holder · Purpose: Educational program / people-to-people group

Yes — but only as part of a U.S.-sponsored educational program.

Authorising regulation: 31 CFR §515.565 — Educational activities and people-to-people exchanges

After the 2019 amendments, individual people-to-people travel is no longer authorised. All educational and people-to-people travel must now be conducted under the auspices of a U.S.-based academic institution or a sponsoring U.S. organisation that maintains the OFAC compliance program for the trip.

Compliance checklist for this trip

  1. Confirm a qualifying U.S. sponsor (university, accredited program, or licensed group operator) is the legal sponsor.
  2. Travel must be in a group with a U.S. representative accompanying the group.
  3. Full-time schedule of educational activities — no free time at resorts.
  4. Sponsor handles OFAC documentation; you should still keep a personal copy of the schedule.
  5. Sponsor must avoid CRL-listed hotels and tour operators — verify before payment.

Cuban-side entry requirements (every traveller, every passport)

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Important: Educational decision aid, not legal advice. CACR (31 CFR Part 515) and the State Department’s Cuba Restricted & Prohibited Accommodations Lists change periodically — verify before booking, and keep full-time-schedule + transaction records for five years per §515.601.
When to retain counselHide
For any high-stakes trip — particularly journalism (§515.561), business travel, group people-to-people travel (§515.565), or anything involving transactions with Cuban government counterparties — retain qualified U.S. sanctions counsel before booking. The CRL changes intra-administration, the CPAL between our refreshes, and OFAC enforcement priorities can shift without notice.

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