Skip to main content
U.S. flag

An official website of the United States government

702. What constitutes "educational activities" for generally authorized travel and other transactions?

Answer

On September 30, 2026, OFAC amended 31 CFR § 515.565(a) to restore particular requirements for authorized educational activities related to Cuba. As of September 30, 2026, the requirements related to a person's use of the educational activities- authorization depend on whether the person engaging in the activity is associated with an accredited U.S. undergraduate or graduate degree-granting academic institution.

Effective September 30, 2026, § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate degree-granting academic institutions and their faculty, staff, and students, to engage in the travel-related transactions set forth in 31 CFR § 515.560(c) and such additional transactions as are directly incident to the six categories of educational activities enumerated in § 515.565(a)(1). Among other educational activities, this general license authorizes, subject to conditions outlined in § 515.565(a)(1), faculty, staff, and students at accredited U.S. undergraduate or graduate degree-granting academic institutions to participate in a structured educational program in Cuba or to teach at a Cuban academic institution, as well as authorizes Cuban scholars to engage in certain educational activities in the United States. For a complete description of authorized educational activities related to accredited U.S. undergraduate or graduate degree-granting academic institutions, and the restrictions that apply, see § 515.565(a)(1).

Effective September 30, 2026, § 515.565(a)(2) authorizes persons subject to U.S. jurisdiction, including, for example, U.S. secondary schools, to engage in additional educational activities that are not authorized under § 515.565(a)(1), provided that: (1) any travel-related transactions pursuant to these authorizations take place under the auspices of an organization that is a person subject to U.S. jurisdiction (the "sponsoring organization"), and (2) all travelers are accompanied by a person subject to U.S. jurisdiction who is an employee, paid consultant, agent, or other representative of the sponsoring organization (subject to certain exceptions). These authorized transactions include the travel-related transactions set forth in § 515.560(c) and such transactions as are directly incident to the 12 categories of educational activities enumerated in § 515.565(a)(2). For example, under this general license, U.S. and Cuban universities may engage in academic exchanges and joint non-commercial academic research, and persons subject to U.S. jurisdiction may provide standardized testing services and certain internet-based courses to Cuban nationals. For a complete description of what this general license authorizes and the restrictions that apply, see § 515.565(a)(2).

Effective September 30, 2026, OFAC further amended § 515.565 to remove the authorization for group people-to-people educational travel.

Please note that the general license at § 515.565 excludes any direct or, effective September 30, 2026, indirect financial transaction with entities and subentities identified on the State Department's Cuba Restricted List. For a description of the scope of the prohibition on direct or indirect financial transactions and the restrictions and exceptions that apply, see § 515.209. This general license also excludes from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210.

Date Updated: September 29, 2026
Date Released
September 23, 2020