§515.574 Support for the Cuban People.
(a) General license. The travel-related transactions set forth in §515.560(c) and other transactions that are intended to provide support for the Cuban people are authorized, provided that:
(1) The activities are of:
(i) Recognized human rights organizations;
(ii) Independent organizations designed to promote a rapid, peaceful transition to democracy; or
(iii) Individuals and non-governmental organizations that promote independent activity intended to strengthen civil society in Cuba; and
(2) Each traveler engages in a full-time schedule of activities that:
(i) Enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people's independence from Cuban authorities; and
(ii) Result in meaningful interaction with individuals in Cuba.
(3) The traveler's schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule.
Note 1 to paragraph (a): Each person relying on...
1) All three of the categories of persons eligible for the SCP GL are expressed in terms with no set definitions and no publicly available interpretive guidance with which to determine the scope. "Individuals...that promote independent activity intended to strengthen civil society in Cuba" is particularly vague, and conducive to including, for example, people with Twitter accounts with which they express pro-Cuban-democracy opinions. Query whether and to what extent OFAC would be likely to interpret 515.574(a)(1)(iii) as, in effect, covering much of the same ground that the "people-to-people" license covered prior to its 2017 restrictive amendment.
2) Refer to FAQ # 707.
3) For guidance relating to the notion of consistency with a "full-time schedule," see Letter from Treasury to Rep. Diaz-Balart re: SCP Cuba Travel; FAQ # 711 and "Prepaid Tourist Packages are...