Travel to and Transactions with Cuba/Cuban Nationals
U.S. laws and regulations prohibit U.S. citizens and residents from traveling to or engaging in any financial transactions relating to Cuba except in connection with certain specified activities.
A. Activities Permitted with Yale Authorization
Yale faculty, staff and students may engage in the following activities after first contacting the Office of General Counsel at 203-432-4949 to discuss the proposed activity, confirm that it comes within the regulations and obtain an authorizing letter to carry in connection with travel to Cuba. A specific license from the U.S. government is not required for these activities.
- Participation in a structured educational program in Cuba as part of a course offered for credit by Yale;
- Noncommercial academic research in Cuba specifically related to Cuba and for the purpose of obtaining a graduate 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 by an individual regularly employed in a teaching capacity at Yale, provided the teaching is related to an academic program at the Cuban institution and will be at least 10 weeks in duration;
- Travelling to Cuba to organize or prepare for any of the activities listed above, provided the individual is faculty or staff;
- Conducting research or attending conferences in Cuba, provided the individual is full time faculty or staff.
Yale students, faculty, and staff who have obtained an authorization letter from the Office of General Counsel may travel to Cuba from airports in the United States (usually Miami) by making their travel arrangements through a travel agency designated by the U.S. government and listed at http://www.treasury.gov/resource-center/sanctions/Programs/pages/cuba.aspx. This website also provides more information on the regulations.
B. Activities Possible with US Government Authorization
The following are examples of activities that require a specific license from the US Government. Individuals interested in such activities sponsored by or under the auspices of Yale must contact the Office of General Counsel. We will provide guidance and support in obtaining the required license.
- Travelling to Cuba in order to export, import, or transmit information or informational materials such as publications, films, photographs, microfiche, and artworks.
- Sponsoring or co-sponsoring academic seminars, conferences, or workshops in Cuba relating to Cuba or global issues involving Cuba.
- Hosting a performance in Cuba.
- Other educational activities that do not fall into one of the categories listed in Section A above.
C. Financial Transactions
Finally, the U.S. Cuban regulations also apply to any financial transaction with a Cuban entity or national. The payment of expenses associated with authorized or licensed activities is permitted and Yale may pay a stipend or salary to a Cuban national to teach or engage in another scholar activity at Yale. However, without a specific license the hiring of Cuban national to serve as a consultant to Yale may not be allowed even if the consultant will be located outside Cuba when performing this work.
In all cases, Yale faculty, staff or students interested in engaging in financial transactions with a Cuban entity or national must first contact the Office of General Counsel at 203-432-4949 to discuss the transaction and determine any compliance limits or requirements.