Thursday, January 27, 2011

Preview of New Cuba Travel Regulations

Along the Malecon just posted that the new OFAC regulations to be published in the Federal Register tomorrow are now available on line.

The Wall Street Journal blog Corruption Currents first broke the news earlier today.

I have yet to go through the 37-page document (available at the links above) in detail myself, but at first glance I have the three following observations:
  • You've got to hand it to the Obama administration in terms of timing and keeping its word.  They said the new regs would be ready "in two weeks" in the announcement on Friday, January 14.  Tomorrow is Friday, January 28.  Exactly two weeks.
  • The regulations seem to stick closely to the details of the previous announcement, with no real surprises (further expanding or more intently policing travel and remittances).
  • However, in my quick once-over of the new regs, I found the following interesting tid-bit on pages 18 and 20 that seems to now make it possible to legally "sponsor" and "pay" Cuban scholars a "stipend or salary" when they visit the U.S. "to teach or engage in other scholarly activity at the sponsoring U.S. academic institution."  Can anyone confirm opr deny my interpretation? 
§ 515.565 Educational activities.
(a) General license. Accredited U.S. graduate and undergraduate degree-granting academic institutions, including faculty, staff, and students of such institutions, are authorized to engage in the travel-related transactions set forth in § 515.560(c) and such additional transactions that are directly incident to:
(5) Sponsorship, including the payment of a stipend or salary, of a Cuban scholar to teach or engage in other scholarly activity at the sponsoring U.S. academic institution (in addition to those transactions authorized by the general license contained in § 515.571). Such earnings may be remitted to Cuba as provided in § 515.570 or carried on the person of the Cuban scholar returning to Cuba as provided in § 515.560(d)(3)

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