Check any Cuban hotel, casa, or resort against the State Department’s prohibited list (CPAL). U.S. persons can’t lawfully stay at properties on this list — even via a third-country booking.
How to read the list:
The Cuba Prohibited Accommodations List (CPAL) is maintained by the U.S. State Department under §515.210 of the Cuban Assets Control Regulations. It identifies specific hotels, hostales, casas particulares, and resorts in Cuba at which U.S. persons are prohibited from staying or paying for lodging — regardless of whether the booking is made through a U.S. or third-country platform like Booking.com or Airbnb. Properties are listed because they are owned or controlled by a Cuban government entity, military holding company (GAESA), or a Communist Party official.
No. They are separate lists published under different sections of the CACR. The CRL (§515.209) lists Cuban entities you cannot transact with (e.g. GAESA, CIMEX, Gaviota). The CPAL (§515.210) lists specific lodging properties. A hotel may be on the CPAL because its operator is on the CRL, but the lists are structurally distinct and you must check both. Neither fully overlaps with the OFAC SDN list.
Genuine independently-owned casas particulares are generally permissible under §515.574 (“Support for the Cuban People”) and are the recommended compliance pattern for U.S. travelers. However, the State Department flags two subcategories on the CPAL: properties marketed as casas but actually state-owned (* marker), and genuine private casas that meet CPAL inclusion criteria (^ marker). Both types are prohibited. Always search this tool before booking.
The §515.210 prohibition follows the U.S. person, not the booking channel. A U.S. citizen staying at a CPAL-listed property is in violation even when the reservation, payment, or platform is foreign. Airbnb operates under separate authorizations (§515.578 telecoms / internet services), but the underlying lodging prohibition still applies to the traveler.