OFAC Issues New Guidelines on Travel to Cuba

The Treasury Department’s Office of Foreign Assets Control on Thursday issued a new set of guidelines regarding travel to Cuba.  This follows on the earlier easing of restrictions on travel by President Obama to the island state.

The new guidelines explain the different categories of travel under the OFAC regulations, effectively that travel which is permitted under General License (i.e., no license application process vis-a-vis OFAC) and those permitted under specific license (e.g., application and formal written approval required).  Although the scope of permitted travel has expanded notably, not all travel is permitted, including general touristic activity. Naturally, this cannot be bypassed by traveling to Cuba via a third country.

Although the guidelines provide extensive information on the scope and nature of the regulations, they obviously do not supplant or substitute the existing sanctions laws on Cuba.  Also, although they appear relatively clear to those who practice in this area of law, the guidelines may be somewhat difficult to interpret for non-lawyers.