711. What are examples of a full-time schedule of activities for authorized travelers?
Authorized travelers to Cuba pursuant to most general license categories are expected to maintain a full-time schedule of activities consistent with the terms of the general license(s) pursuant to which they are traveling. For example:
*An individual traveling to Cuba for four days pursuant to the authorization for professional research (31 CFR § 515.564(a)), such as a professional architect, could conduct two days of research on Cuban architectural heritage that directly relates to the traveler’s profession, followed by one day of meetings with Cuban nationals engaging in historical preservation of colonial and baroque buildings in Havana. The following day the traveler could engage in a full day of site visits and fact-finding around Havana at key architectural sites.
*An individual traveling pursuant to the authorization for journalistic activities could engage in three full days of interviews with local residents, followed by one full day of follow-up investigative research at local institutions.
*A group of friends traveling to Cuba could maintain a full-time schedule volunteering with a recognized non-governmental organization to build a school for underserved Cuban children with the local community (31 CFR § 515.574). The travelers would need to ensure that their activities promote independent activity intended to strengthen civil society in Cuba and that they engage in a full-time schedule of activities that enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence from Cuban authorities, and result in meaningful interaction between the travelers and individuals in Cuba.
09/23/2020
1) Examples bearing on the notion of "full-time schedule" are relevant for all travel General Licenses. See other examples relating to the notion of "full-time schedule" at 515.574.
2) Refer to License No. CT-2012-294798-1; Case No. CT-2012-294798-1, Letter from Treasury to Rep. Diaz-Balart re: SCP Cuba Travel, and Prepaid Tourist Packages are Prohibited (2001) for more on the relationship between fulfillment of the "full time schedule" requirement and tourist activities.
3) FAQ amended on 9-23-2020 to amend the example used. Prior to the amendment, the 2nd paragraph read as follows:
“An individual traveling to Cuba for four days pursuant to the authorization for professional research and professional meetings (31 CFR § 515.564(a)), such as a professional architect, could participate in a two-day conference on Cuban architecture that directly relates to the traveler’s profession, followed by one day of meetings with Cuban nationals engaging in historical preservation of colonial and baroque buildings in Havana. The following day the traveler could engage in a full day of site visits and fact-finding around Havana at key architectural sites.”
This change was made in light of the amendment to 515.564(a) that removed the GL for “professional meetings or conferences in Cuba.” It is not, however, clear whether, in all cases, the attendance of “a two-day conference on Cuban architecture” would be outside the scope of the current 515.565(a) for a “professional architect.” It would depend on whether attendance at the conference could constitute “professional research.”