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Asked in @US Sep. 23, 2020 ,  0 answers
702. What constitutes “educational activities” for generally authorized travel and other transactions?
Data From  US_Treasury_QA_Question

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Anonymous
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Posted on / Sep. 23, 2020 00:00:00 OFAC amended the general license for educational activities in accordance with NSPM-5 process to authorize travel that was permitted by regulation on January 27, 2011. In addition, OFAC added requirements for certain categories of authorized educational travel that were not permitted by regulation on January 27, 2011 to require that all such travel be conducted under the auspices of an organization that is a person subject to U.S. jurisdiction. In addition, travelers utilizing this authorization must be accompanied by a person subject to U.S. jurisdiction who is a representative of the sponsoring organization. In certain cases where the traveler is an employee, paid consultant, agent, or other representative traveling individually (not as part of a group), the individual may obtain a certification letter from the sponsoring organization. For a complete description of what such a letter must include and which categories of educational travelers may utilize this authorization, see 31 CFR § 515.565(a)(2).Among other things, this general license authorizes, subject to conditions, faculty, staff, and students at U.S. academic institutions and secondary schools to engage in certain educational activities, including study abroad programs, in Cuba, Cuban scholars to engage in certain educational activities in the United States, and certain activities to facilitate licensed educational programs. U.S. and Cuban universities may engage in academic exchanges and joint non-commercial academic research under the general license. This provision also authorizes persons subject to U.S. jurisdiction to provide standardized testing services and certain internet-based courses to Cuban nationals. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.565.In accordance with NSPM-5, this general license  excludes direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. For a description of the scope of the prohibition on direct financial transactions and the restrictions and exceptions that apply, see 31 CFR § 515.209 Also, and effective September 24, 2020, OFAC amended this general license to exclude from the authorization lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210. Effective June 5, 2019, OFAC removed the authorization for group people-to-people educational travel. For more information on that change, see FAQ 704.) [09-23-2020]

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