Economic Sanctions and Embargoes
Travel to and Transactions with Cuba and Cuban Nationals
U.S. laws and regulations prohibit U.S. persons from traveling to or engaging in any financial transactions relating to Cuba except in connection with certain activities as described below. Those qualifying as U.S. persons for this purpose include:
- U.S. citizens and residents;
- anyone (including citizen and residents of other countries) traveling to Cuba directly from the U.S.; or
- anyone (including citizen and residents of other countries) traveling to Cuba using Yale funding or in connection with a Yale activity, whether they travel to Cuba directly from the U.S. or from another country.
In December 2014, President Obama announced a new era of U.S. - Cuba relations. However, restrictions on travel to Cuba remain in place and trips to Cuba that are primarily tourist-oriented and many other transactions relating to Cuba continue to be prohibited.
Section 1: Permitted Activities
Yale faculty, staff and students may travel to Cuba to engage in the educational activities listed below without needing to apply for pre-authorization from the U.S. Government. The list below is not intended to be exhaustive but rather gives an overview of the categories most relevant to the Yale community and the requirements for each activity type.
Please note that even if travel to Cuba is permissible, Yale faculty, students, and staff may not engage in transactions with entities on the State Department’s restricted list which is available at: https://www.state.gov/e/eb/tfs/spi/cuba/cubarestrictedlist/275331.htm. Restricted parties include certain hotels, stores, and other entities.
In addition, U.S. regulations require travelers to Cuba to retain for five years, full and accurate records demonstrating that the activity was permitted and was not primarily tourist-oriented.
Category A: Academic Study, Teaching, or Student Research Activities
All Yale students, faculty and staff wishing to engage in a Category A activity listed below, must first receive a letter from Yale that states that their travel meets the regulatory requirements. To receive this letter, please contact the Office of General Counsel by emailing firstname.lastname@example.org and providing a detailed description of the activity you wish to engage in.
Students wishing to engage in Category A activities, with the exception of item #2 listed below, must travel to Cuba for at least ten weeks, unless the student, is accompanied by a Yale faculty or staff member.
Full-time faculty or staff may travel for less than 10 weeks.
Category A activities are:
- Participation in a structured educational program in Cuba as part of a for-credit course sponsored by Yale;
- Engaging in noncommercial academic research in Cuba specifically related to Cuba for the purpose of obtaining a graduate degree from Yale, or an undergraduate degree if the undergraduate student is accompanied by Yale faculty or staff member;
- Participation in a formal course of study at a Cuban academic institution provided Yale will accept the formal course of study for credit toward the student’s graduate or undergraduate degree;
- Teaching at a Cuban academic institution related to an academic program at the Cuban institution, provided the individual is a full-time employee of Yale regularly engaged in teaching; or
- The organization of, and preparation for, activities described above by full-time Yale faculty and staff.
Category B: Professional Research and Meetings
Yale faculty, staff and graduate students may travel to Cuba to conduct professional research or attend a professional meeting provided that the following conditions apply:
- The purpose of the research or meeting directly relates to the traveler’s profession, professional background, or area of expertise, including area of full-time graduate study;
- The purpose of meetings and conferences attended is not the promotion of tourism in Cuba;
- The traveler doesn’t engage in recreational or tourist travel, travel in pursuit of a hobby, or research for personal satisfaction only; and
- The traveler’s schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule of professional research or a full-time schedule of professional meeting and conference attendance.
Those engaging in Category B activities are not required to travel with a letter from Yale; however, they must still travel with documentation that demonstrates that they meet the requirements listed above and must retain this documentation for 5 years. Individuals with questions regarding Category B activities should contact the Office of General Counsel by emailing email@example.com.
Category C: Other Educational Activities
All Yale faculty and staff wishing to engage in a Category C activity listed below, must first receive a letter from Yale that states that their travel meets the regulatory requirements. To receive this letter, please contact the Office of General Counsel by emailing firstname.lastname@example.org and providing a detailed description of the activity you wish to engage in.
Yale students may engage in Category C activities if they are accompanied by a Yale faculty or staff member.
- Sponsorship or co-sponsorship of noncommercial academic seminars, conferences, symposia, and workshops related to Cuba or global issues involving Cuba; Yale faculty, staff, and students may also attend such events.
- Establishment of academic exchanges and joint non-commercial academic research projects with Cuban universities or academic institutions.
- Participation in a “people to people” trip. A people to people trip is an educational trip that promotes meaningful interaction between the traveler and individuals in Cuba. It is not a trip involving academic study pursuant to a degree program. Yale faculty, students and staff can engage in such a trip provided (i) the purpose of the trip is to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities; (ii) each traveler has a full-time schedule of activities that will result in a meaningful interaction between the traveler and individuals in Cuba; (iii) the predominant portion of the trip does not involve interactions with individuals or entities acting on behalf of prohibited officials of the Government of Cuba or prohibited members of the Cuban Communist party; and (iv) a Yale Representative, or a representative of the organization sponsoring the trip if the trip is not sponsored by Yale, must accompany the group to ensure that each traveler complies with these requirements.
Note: effective June 16, 2017, individual people-to-people travel to Cuba is no longer permitted unless the individual traveler has already completed one or more transactions prior to that date (e.g., purchased a plane ticket or made hotel reservations) in preparation for an upcoming individual people-to-people trip to Cuba.
Section 2: Other Permitted Activities
Activities in addition to those described in Section 1 above may be permissible. For example, the regulations allow travel to engage in certain religious or humanitarian activities, to host performances or athletic competitions, or to export or import certain informational materials.
In addition, educational activities not listed above may be permitted if you apply for pre-authorization from the U.S. government in the form of a “specific license.”
Individuals interested in activities sponsored by or under the auspices of Yale not listed in Section 1 must contact the Office of General Counsel by emailing email@example.com for guidance and assistance.
Section 3: Financial Transactions with Cuban Nationals (not involving travel to Cuba)
Yale may pay a stipend or salary to bring a Cuban national to Yale to teach or engage in other scholarly activity. The regulations also allow Yale to engage in financial transactions necessary and ordinarily incident to publishing and marketing of manuscripts, books, journals and newspapers. For example, Yale can commission manuscripts and pay royalties to Cuban nationals. Yale can also pay Cuban nationals to create, disseminate, alter, or enhance informational materials such as films and artworks.
Section 4: Financial Transactions Possible with U.S. Government Authorization
Financial transactions with Cuban entities or Cuban nationals other than those described above may not be permissible or may require a specific license. Individuals interested in engaging in such transactions must first contact the Office of General Counsel by emailing firstname.lastname@example.org to discuss the transaction and determine any compliance limits or requirements.