Yes — qualifying private foundations and institutes are authorised.
Authorising regulation: 31 CFR §515.576 — Activities of private foundations or research or educational institutes
Authorises travel for U.S. private foundations or research / educational institutes that have an established interest in international relations, to collect information not generally available and to conduct programs not for profit.
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.