Yes — your trip is authorised under “support for the Cuban people.”
Authorising regulation: 31 CFR §515.574 — Support for the Cuban People
This is the only individual self-organised category that survived the 2019 Trump-era restrictions. It requires a full-time schedule of activities that meaningfully interact with Cubans — staying in casas particulares, eating at paladares, hiring independent guides, and supporting MIPYME businesses. Pure beach-and-resort itineraries do not qualify.
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.