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.
While recent changes to U.S. sanctions on Cuba have eased restrictions on travel somewhat, 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/cuba-sanctions/cuba-restricted-list/. 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.
Individuals with questions regarding any of the activities listed below should contact the Office of Export Controls by emailing mark.stomski@yale.edu.
Category A: Academic Study, Teaching, or Student Research Activities
Yale faculty, staff, graduate and undergraduate students may travel to Cuba to engage in academic study, teaching, or student research activities as described below:
- 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 or undergraduate degree from Yale;
- 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 Yale faculty and staff.
Category B: Professional Research
Yale faculty, staff and graduate students may travel to Cuba to conduct professional research provided that the following conditions apply:
- The purpose of the research directly relates to the traveler’s profession, professional background, or area of expertise, including area of full-time graduate study; 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.
Category C: Other Educational Activities
Yale faculty and staff may travel to Cuba to engage in the following activities:
- 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; or
- The organization of, and preparation for, activities described above by Yale faculty and staff.
Yale faculty, staff and students may participate in group educational exchanges that do not involve academic study for the purpose of obtaining a graduate or undergraduate degree (“People-to-People Travel”), provided that the following conditions apply:
- The exchange takes place under the auspices of an organization that is subject to U.S. jurisdiction and that sponsors such exchanges;
- The traveler’s transactions must be for the purpose of engaging, while in Cuba, in activities intended to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities; and
- The group is accompanied by an employee, paid consultant, or agent of the sponsoring organization to ensure that each traveler has a full-time schedule of educational exchange activities that will result in meaningful interaction between the traveler and individuals in 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 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 Export Controls by emailing mark.stomski@yale.edu 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 Export Controls by emailing mark.stomski@yale.edu to discuss the transaction and determine any compliance limits or requirements.