Navigating the Cuban Travel Maze: Your Guide to OFAC Restrictions
By: Adolfo Nodal
Welcome to the wonderfully complex world of OFAC travel restrictions to Cuba – where the acronyms are plentiful, the regulations are detailed, and the penalties for getting it wrong are decidedly unfunny. But don't worry! While navigating these draconian waters might seem as challenging as solving a Rubik's cube blindfolded, we're here to break it all down for you in plain English, with just enough humor to keep you awake through the regulatory details. When you travel to Cuba with Project Por Amor, this legal labyrinth is completely taken care of for you like a magic carpet ride out of a confusing federal bureaucracy. But if you’re traveling on your own, or still interested in understanding how it all works, read on. Full disclosure: THIS IS NOT LEGAL ADVICE. It's just a short guide from Project Por Amor to help you sort it out.
The Office of Foreign Assets Control (OFAC), part of the U.S. Department of Treasury, is the federal agency that oversees economic sanctions programs, including the comprehensive restrictions on Cuba that have been in place for over six decades [1]. These regulations, formally known as the Cuban Assets Control Regulations (CACR), are codified in Title 31 of the Code of Federal Regulations, specifically 31 CFR Part 515 [2]. Think of OFAC as the stern but fair referee in the complex game of international relations – they set the rules, monitor compliance, and issue penalties when those rules are broken.
The current framework for Cuba travel emerged from decades of evolving U.S.-Cuba relations, with the most recent significant changes occurring in 2022 when OFAC amended several key provisions to allow for expanded educational and people-to-people exchanges [3]. Understanding these regulations isn't just about avoiding legal trouble – it's about ensuring that your Cuban adventure contributes positively to the Cuban people while staying within the bounds of U.S. law.
The Foundation: Understanding OFAC’s 12 Categories of Legal Travel
Before exploring the specifics of the most popular travel categories, it’s essential to recognize that tourist travel to Cuba remains strictly prohibited for U.S. citizens and residents [4]. This isn’t a mere guideline—it’s federal law, with potential civil penalties reaching hundreds of thousands of dollars for violations.
However, the Office of Foreign Assets Control (OFAC) has established twelve specific categories under which Americans can legally travel to Cuba, each accompanied by its own requirements, restrictions, and documentation obligations.
Outlined in 31 CFR § 515.560(a), these twelve categories represent the only lawful pathways for U.S. persons to engage in travel-related transactions with Cuba [5]. Designed to promote distinct policy objectives—ranging from supporting Cuban civil society to facilitating legitimate business, educational, and humanitarian activities—each category operates under a “general license.” This means travelers who meet the specific criteria don’t need to seek individual OFAC permission, but they must maintain detailed records and ensure strict compliance with all applicable restrictions.
The authorized categories are:
Family visits
Official business of the U.S. government, foreign governments, and certain intergovernmental organizations
Journalistic activity
Professional research and professional meetings
Educational activities
Religious activities
Athletic competitions by amateur or semi-professional athletes or teams
Support for the Cuban people
Humanitarian projects
Activities of private foundations or research or educational institutes
Exportation, importation, or transmission of information or informational materials
What makes these regulations especially nuanced is that each category has specific requirements for documentation, activity schedules, and prohibited transactions. Travelers must not only qualify for a category but also navigate a complex landscape of restricted entities, prohibited accommodations, and financial transaction limitations that apply across all categories. Many well-intentioned travelers focus on qualifying but overlook these broader restrictions, which can invalidate their entire trip.
Cuban flag in front of monument to Calixto Garcia, a General in Cuba’s War of Independence
"Support for the Cuban People": The Most Accessible Path to Cuban Adventure
Among OFAC’s twelve authorized travel categories, “Support for the Cuban People” is the most popular and accessible option for Americans eager to explore Cuba’s vibrant culture, history, and natural beauty. Established under 31 CFR § 515.574, this category aims to ensure that U.S. tourism dollars benefit Cuban citizens and private businesses rather than government-controlled entities [7].
Most Project Por Amor tours fall under this category, though they often also qualify as People-to-People Educational Travel. The strength of this category lies in its alignment of traveler interests with U.S. policy goals: when you enjoy a handcrafted mojito at a privately owned paladar or learn salsa from a local instructor, you’re directly supporting Cuban entrepreneurs and civil society. It’s a rare win-win in the complex landscape of international sanctions.
The Legal Framework: What the Regulation Actually Says
The “Support for the Cuban People” general license permits travel-related activities aimed at providing support to Cuban citizens [8]. Travelers must meet three key requirements:
Activities must fall into one of three categories: recognized human rights groups, independent organizations promoting peaceful democratic transition, or NGOs and individuals fostering independent civil society in Cuba [9]. This broadly includes private lodging, cooking classes, and artistic interactions.
Travelers must maintain a full-time schedule of meaningful activities that enhance contact with Cubans, support civil society, or promote independence from Cuban authorities [10]. This is not a casual vacation—substantive engagement is required.
Leisure and free time must be limited and secondary to support activities, following an 80/20 balance—most time spent on qualifying activities, with reasonable downtime [11].
Practical Applications: What This Looks Like in Real Life
The regulation highlights specific activities that qualify under the Support for the Cuban People license, illustrating the authentic, people-to-people travel experience:
Staying in casas particulares (private family-run homes) offers intimate cultural immersion while directly supporting Cuban families [12].
Dining at paladares, privately-owned restaurants, supports Cuba’s entrepreneurial spirit and culinary innovation [13].
Shopping from cuentapropistas—self-employed Cuban small business owners—helps sustain local artisans, independent farmers, and boutique owners [14].
However, the regulation stresses that these activities alone don’t fulfill the required full-time schedule. Travelers must also engage in deeper involvement, such as supporting new business ventures, volunteering with recognized NGOs, or participating in community development projects [15].
The Art of Itinerary Planning: Building a Compliant Schedule
To comply with the Support for the Cuban People category, an itinerary must show genuine, meaningful engagement with Cuban civil society alongside travel enjoyment.
A compliant schedule might include activities like:
Morning Spanish lessons with a private tutor
Visits to independent artist studios and galleries
Private performances and discussions with dance companies
Home-cooked meals and visits at sustainable farms
Conversations with Cuban professors on economics
Dining at various paladares while engaging with owners
Rooftop jazz concerts at privately-owned venues
Cooking or dance classes with local professionals
Guided tours by independent Cuban experts
In contrast, plans centered on casual sightseeing, like renting a bike to explore with only brief local exchanges, do not qualify [17]. Such itineraries lack the substantive interaction the license mandates and are considered typical tourism rather than authorized travel.
Documentation and Record-Keeping: Your Legal Insurance Policy
Travelers under the Support for the Cuban People category must keep detailed records of their activities and expenses, as required by 31 CFR § 501.601 and 501.602 [18]. This includes daily itineraries, receipts from private businesses, and documentation of interactions with Cuban individuals and organizations.
Maintaining these records isn’t just paperwork — it’s your protection if OFAC questions your compliance. While audits are rare, travelers without proper documentation risk heavy penalties.
On Project Por Amor tours, this process is streamlined since the trip app organizes your itinerary and all important documentation for easy record-keeping.
Cuba’s Capitol building
"People to People" Travel: The Rise, Fall, and Partial Resurrection of Educational Exchange
The "People to People" category has perhaps the most dramatic regulatory history of all the Cuba travel authorizations. Understanding this category's evolution provides crucial insight into how U.S.-Cuba policy has shifted over the past decade and what options are currently available to travelers.
The Historical Context: From Boom to Bust to Cautious Revival
The People to People program began under President Clinton in 1999 to encourage educational exchanges fostering mutual understanding between Americans and Cubans. It grew rapidly, enabling many Americans to visit Cuba with self-designed educational itineraries.
In 2017, the Trump administration ended individual People to People travel, closing a popular route for travelers.
The Biden administration’s 2022 changes struck a middle ground by allowing group People to People educational travel under specific rules, rather than fully restoring individual travel.
Current Regulations: Group Travel Only, With Strict Requirements
As of now, individual People to People travel is prohibited under U.S. law. Only group People to People educational travel is allowed, and it must be:
Sponsored by a U.S.-based organization (like Project Por Amor), and
Accompanied by a representative of that organization to ensure the trip includes meaningful educational engagement and complies with federal rules.
Travelers cannot self-design or lead their own People to People trips—doing so would violate U.S. sanctions.
The Educational Imperative: What Makes Travel “Educational”
People to People travel must follow a full-time schedule of educational activities that foster meaningful interactions with Cuban individuals. While it shares some similarities with the “Support for the Cuban People” category, this license specifically requires an educational purpose—focused on deepening understanding of Cuban culture, history, politics, or society.
This means that activities like lectures by Cuban scholars, museum visits, and meetings with professionals are essential. Simply staying in private homes or dining at paladares isn’t enough on its own.
People to People programs are typically intensive and structured, with little free time. They’re ideal for travelers who want an immersive and educational experience, but not a good fit for those looking for a leisurely vacation.
Project Por Amor group in discussion with a Cuban professor of the University of Santiago
Choosing the Right Organization: Do Your Homework
Because individual People to People travel is no longer allowed, travelers must go through a U.S.-based organization authorized to run group educational programs in Cuba. Not all providers are compliant, so it’s important to choose carefully.
Look for organizations with real experience in Cuba, strong ties to local institutions, and a clear understanding of OFAC rules. They should be able to provide proper documentation and detailed, education-focused itineraries.
Avoid any group that downplays the educational component or sells the trip as just a legal vacation. The most reputable programs treat compliance as a chance to foster real cross-cultural connection and learning—not just check a box.
The Future of People to People Travel
The 2022 reinstatement of group People to People travel signals cautious progress, but individual travel under this category remains off the table—and likely will for some time. These continued restrictions aim to ensure U.S. travel to Cuba supports genuine educational and policy goals, not casual tourism.
For travelers, this means People to People trips will remain more structured—and often more costly—than other legal categories like “Support for the Cuban People.” But for those truly interested in Cuba’s culture, history, and society, these programs offer rare, in-depth access to Cuban institutions and experts.
The key is mindset: this category is for travelers who prioritize learning and meaningful engagement, not leisure. When done right, People to People travel can be one of the most enriching ways to experience Cuba.
Preservation Hall Jazz Band celebration with locals in Lajas, Cuba
The Other Ten: A Quick Guide to Alternative Travel Categories
While "Support for the Cuban People" and "People to People" travel capture most of the attention in discussions about Cuba travel, the other ten authorized categories serve important functions and may be more appropriate for certain travelers depending on their circumstances, professional obligations, or personal connections to Cuba.
Family Visits
Authorized under 31 CFR § 515.561, this category allows U.S. persons to visit close relatives in Cuba, including those up to three generations removed by blood, marriage, or adoption [25][26]. It’s the most straightforward category, but travelers must still avoid prohibited accommodations and restricted entities.
Official Government Business
Under 31 CFR § 515.562, this authorizes travel for U.S. and foreign government employees and representatives of intergovernmental organizations like the UN or WHO [27]. It facilitates diplomatic and official engagement.
Journalistic Activity
Codified in 31 CFR § 515.563, this permits journalists and media professionals to conduct legitimate news gathering in Cuba [28]. Freelancers may qualify if they demonstrate professional credentials and intent.
Professional Research and Professional Meetings
Allowed under 31 CFR § 515.564, this category includes travel for academic research or attending professional conferences [29]. It must be clearly tied to the traveler’s profession or field of expertise.
Educational Activities
Found in 31 CFR § 515.565(a), this supports study abroad programs, academic exchanges, and other structured learning experiences outside of the People to People subcategory [30]. It is most commonly used by universities and educational institutions.
Religious Activities
Authorized under 31 CFR § 515.566, this permits faith-based travel including ministry, religious education, and participation in religious events [31]. Travelers must be affiliated with a recognized religious organization.
Athletic Competitions
Under 31 CFR § 515.567, this category allows amateur and semi-pro athletes or teams to compete or train in Cuba as part of organized sports exchanges [32]. It supports cultural diplomacy through athletics.
Humanitarian Projects
Outlined in 31 CFR § 515.575, this permits charitable work such as disaster relief, medical aid, or other projects addressing basic human needs [33]. Activities must be coordinated with a recognized humanitarian group.
Activities of Private Foundations and Research Institutes
This category, under 31 CFR § 515.576, allows staff of private institutions to conduct educational, research, or charitable work in Cuba [34]. It’s often used by foundations, universities, and think tanks.
Information and Informational Materials
Authorized in 31 CFR § 515.577, this category covers publishing, broadcasting, and the exchange of informational content [35]. It supports media freedom and the flow of ideas between Cuba and the U.S.
The Minefield of Restrictions: What You Cannot Do (And Why It Matters)
Understanding what you can do in Cuba is only half the battle – equally important is understanding what you cannot do. OFAC has established several categories of prohibited activities and transactions that apply across all travel categories, and violations of these restrictions can invalidate an otherwise compliant trip and result in significant penalties.
The Cuba Restricted List: Avoiding Government-Controlled Entities
U.S. travelers to Cuba are prohibited from making direct financial transactions with entities on the State Department's Cuba Restricted List, which includes companies controlled by the Cuban military, intelligence, or security services [36][37]. This restriction prevents booking hotels, tours, or services with these entities to ensure that U.S. dollars support the Cuban people instead of the government’s security apparatus. Since many large Cuban companies are on this list, travelers must carefully verify businesses beforehand and can often find alternatives in Cuba’s private sector.
Cuban government buildling in Havana
The Cuba Prohibited Accommodations List: Where You Cannot Stay
U.S. travelers are prohibited from staying, booking, or paying for lodging at properties owned or controlled by the Cuban government, certain Cuban officials, or prohibited Communist Party members, as listed in the Cuba Prohibited Accommodations List maintained by the State Department [38][39]. Travelers must verify their accommodations do not appear on this list before travel. Fortunately, privately owned casas particulares offer authentic and legal alternatives, often with better service and prices than government hotels, though they tend to book up quickly due to high demand.
Financial Restrictions: The Cash-Only Reality
Due to U.S. banking restrictions, American travelers generally cannot use credit or debit cards in Cuba and must bring enough cash to cover all expenses during their trip [40]. This cash-only system poses logistical and security challenges and requires travelers to carefully track and keep receipts for all spending to maintain OFAC compliance. Project Por Amor tours provide guidance on cash needs and detailed spending records to help travelers stay compliant.
Import and Export Restrictions: What You Can and Cannot Bring
Travelers must navigate import and export rules when going to and from Cuba. Notably, bringing Cuban alcohol and tobacco products, such as cigars and rum, into the U.S. is prohibited even for personal use [41]. Violations can lead to confiscation and penalties. Additionally, some items like electronics or medical supplies may require special authorization or face Cuban customs restrictions, so it’s important to research regulations before packing.
Practical Considerations: Making Your Cuban Adventure a Reality
Beyond the legal requirements and restrictions, successful Cuba travel requires careful attention to practical considerations that can make the difference between a smooth, enjoyable trip and a logistical nightmare. From obtaining the necessary Cuban e-visa to navigating the country's unique infrastructure challenges, preparation is key to a successful Cuban adventure.
The Cuban Tourist Card: Your Entry Ticket
Before traveling to Cuba, all Americans must obtain a Cuban tourist card (now issued as an electronic visa or e-visa), regardless of their OFAC travel category [42]. This e-visa permits stays of up to 90 days and is included with Project Por Amor tours. Individual travelers can get it through Project Por Amor, airlines, Cuban consulates, or authorized vendors.
Airlines often provide the e-visa digitally for around $50–$100, and online services offer expedited processing. It’s important to understand that the e-visa allows entry into Cuba but does not replace the need for proper U.S. legal authorization under OFAC.
Cuban Embassy in Washington D.C.
Departure and Return: What to Expect at Airports
Departing for Cuba is similar to other international flights but expect extra scrutiny regarding your travel purpose. Some airlines and airports have added documentation checks and security screening specifically for Cuba flights.
Upon return to the U.S., customs officials may ask about your trip and any goods you’re bringing back. Carrying a physical itinerary and proof of OFAC-compliant activities can help speed up the process. Remember, Cuban alcohol and tobacco products are prohibited and subject to confiscation and penalties, while other items like artwork and crafts are usually allowed but may incur standard customs duties.
Infrastructure Challenges: Preparing for a Different Reality
Cuba’s infrastructure poses unique challenges for travelers. Frequent power outages mean packing essentials like portable chargers and flashlights is a must [43]. Internet access is limited and often slow, so downloading maps and apps before arrival is highly recommended.
Getting around can also be tricky—rental cars are costly and gasoline is scarce, while public transportation is often unreliable and crowded. Many visitors prefer hiring private drivers or ride-sharing for convenience. Joining a guided tour can simplify transportation, as it typically handles all travel logistics.
The Bottom Line: Embracing Cuba’s Complexity
Traveling to Cuba as an American means navigating a complex set of regulations, restrictions, and practical challenges. But for those willing to prepare and approach the journey thoughtfully, Cuba offers a truly unique and rewarding travel experience. Its rich history, vibrant culture, stunning landscapes, and resilient people create an environment unlike any other.
Success lies not just in avoiding legal trouble, but in purposeful travel that respects the complex political realities of U.S.-Cuba relations. Whether traveling under "Support for the Cuban People," joining a “People to People” program, or another authorized category, your trip can build bridges between two peoples who share much more than their governments’ policies reveal. These regulations, though daunting, are designed to foster meaningful exchange while ensuring American travel aligns with the embargo’s goals of stagnating their economic growth.
As relations evolve, rules may shift, but Cuba’s enduring appeal—its people, culture, and beauty—remains. For Americans willing to travel thoughtfully and respectfully, Cuba offers a chance to experience one of the world’s most fascinating places while supporting positive change and mutual understanding.
Whether on a guided cultural tour or exploring independently, bring your sense of adventure, plenty of cash, some Spanish, and an open mind. Cuba awaits—ready to challenge your assumptions, broaden your horizons, and create memories that last a lifetime.
Viñales horses in Cuba
References:
[1] Office of Foreign Assets Control, "Cuba Sanctions," U.S. Department of Treasury, https://ofac.treasury.gov/sanctions-programs-and-country-information/cuba-sanctions
[2] "31 CFR Part 515 - Cuban Assets Control Regulations," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515
[3] Office of Foreign Assets Control, "What are the general travel authorizations in the Cuba program?" FAQ 695, https://ofac.treasury.gov/faqs/695
[4] Office of Foreign Assets Control, "Is travel to Cuba for tourist activities permitted?" FAQ 698, https://ofac.treasury.gov/faqs/698
[5] "31 CFR § 515.560 - Travel-related transactions," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.560
[6] Office of Foreign Assets Control, "What are the general travel authorizations in the Cuba program?" FAQ 695, https://ofac.treasury.gov/faqs/695
[7] "31 CFR § 515.574 - Support for the Cuban People," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.574
[8] Ibid.
[9] Ibid.
[10] Ibid.
[11] Ibid.
[12] Ibid.
[13] Ibid.
[14] Ibid.
[15] Ibid.
[16] Ibid.
[17] Ibid.
[18] "31 CFR §§ 501.601 and 501.602," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-501
[19] Office of Foreign Assets Control, "Can travelers engage in 'people-to-people travel' to Cuba on an individual basis or as a part of a group?" FAQ 704, https://ofac.treasury.gov/faqs/704
[20] Ibid.
[21] Ibid.
[22] "31 CFR § 515.565(b)," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.565
[23] Ibid.
[24] Ibid.
[25] "31 CFR § 515.561 - Family visits," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.561
[26] "31 CFR § 515.339 - Close relative," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-C/section-515.339
[27] "31 CFR § 515.562 - Official business of the U.S. government, foreign governments, and certain intergovernmental organizations," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.562
[28] "31 CFR § 515.563 - Journalistic activity," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.563
[29] "31 CFR § 515.564 - Professional research and professional meetings," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.564
[30] "31 CFR § 515.565(a) - Educational activities," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.565
[31] "31 CFR § 515.566 - Religious activities," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.566
[32] "31 CFR § 515.567 - Public performances, clinics, workshops, athletic and other competitions, and exhibitions," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.567
[33] "31 CFR § 515.575 - Humanitarian projects," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.575
[34] "31 CFR § 515.576 - Activities of private foundations or research or educational institutes," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.576
[35] "31 CFR § 515.577 - Exportation, importation, or transmission of information or informational materials," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.577
[36] "State Department's List of Restricted Entities and Subentities Associated with Cuba," U.S. Department of State, https://www.state.gov/cuba-restricted-list/
[37] "31 CFR § 515.209 - Prohibition on direct financial transactions with certain entities and subentities," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-B/section-515.209
[38] "31 CFR § 515.210 - Prohibition on lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property on the Cuba Prohibited Accommodations List," Code of Federal Regulations, https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-B/section-515.210
[39] "Cuba Prohibited Accommodations List," U.S. Department of State, https://www.state.gov/cuba-prohibited-accommodations-list/
[40] U.S. Embassy in Cuba, "Traveling to Cuba," https://cu.usembassy.gov/services/traveling-to-cuba/
[41] Ibid.
[42] Ibid.
[43] U.S. Department of State, "Cuba International Travel Information," https://travel.state.gov/content/travel/en/international-travel/International-