Authorized Travel to and Activities within the Crimea region of Ukraine, North Korea, Sudan, or Syria
The U.S. Department of Treasury website has information about these sanctions programs, including brochures, advisories, and Frequently Asked Questions, which can be found at https://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/Programs.aspx
While travel to these countries is not necessarily prohibited, university activity that would potentially take place while in these countries may require a Specific License from the Office of Foreign Assets Control and the export (even temporarily) of certain items may require an export license. The Export Compliance Officer makes determinations about license applicability. Applications for licenses should be made at least 6 months before the activity begins and before travel arrangements are made.
Each of these countries is subject to sanctions and/or embargo restrictions. For example, there is a prohibition on the export of services to both Sudan and Syria, which means that even simply attending an academic conference or engaging in field research in those countries may require a Specific License from the U.S. Department of Treasury.
In addition to sanctions limiting activities in Sudan and Syria, both countries, as well as the Crimea region of Ukraine and North Korea, are subject to varying degrees of export embargoes.
For travel to or activity within these countries, sanctions and export compliance is required.
Authorized Travel to and Activities within Cuba
The changes removed the need for specific permission from the Treasury Department for certain authorized travel to Cuba. Travel is now broadly authorized under the following General Licenses:
- 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
- Public performances, clinics, workshops, athletic and other competitions, and exhibitions
- Support for the Cuban people
- Humanitarian projects
- Activities of private foundations or research or educational institutes
- Exportation, importation or transmission of information or information materials
- Certain authorized export transactions.
Please note that each of these General License categories have specific conditions that must be met for the travel to be authorized. Travel that does not fall within the specifications of any of these twelve categories will require specific permission from the Treasury Department. The Export Compliance Officer will ascertain what category the travel falls within.
Travelers to Cuba must keep records of any travel-related transactions for five years. The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule related to the authorized travel in Cuba. Further information about the University’s international travel policies may be found here.
Imports from Cuba
Importation of goods from Cuba, for personal use and consumption only, into the United States upon returning form authorized travel to Cuba are now allowed with no restrictions. Personal use includes giving items as personal gifts to other individuals, but not the transfer of an item to another person for payment or other consideration.
Financial Transactions in Cuba
U.S. financial institutions are now permitted to process the payment of credit cards, debit cards, stored value cards, checks, drafts, travelers’ checks, and similar instruments that authorized travelers use in Cuba. Please check with your financial institution to make sure that your payment methods will be accepted, as it may take some time to establish the payment systems.
Exports to Cuba
Anything that you take with you to Cuba is considered an export under the regulations. Specific prior permission, in the form of a license from the Department of Commerce, is still required if travelers to Cuba want to take university owned equipment with them, unless the License Exception “Support for the Cuban People” is available. Personal items may be taken to Cuba, pursuant to Commerce Department license exception “BAG.” An additional license exception for Agricultural Commodities may be available. The Export Compliance Officer makes determinations on the applicability of license exceptions.
Air Travel to Cuba
Travel to and activities within Cuba will be reviewed and approved by the Office of Export Control, in conjunction with the Office of International Education, where appropriate. Pursuant to Accounts Payable Policy, failure to submit a timely Travel Authority prior to traveling to Cuba may result in denial of the reimbursement claim. For more information visit the Export Control Website.