1. How will OFAC implement the changes to the Cuba sanctions program announced
by the President on June 16, 2017? Are the changes effective immediately?
OFAC will implement the Treasury-specific changes via amendments to its Cuban Assets
Control Regulations. The Department of Commerce will implement any necessary
changes via amendments to its Export Administration Regulations. OFAC expects to
issue its regulatory amendments in the coming months. The announced changes do not
take effect until the new regulations are issued.

2. What is individual people-to-people travel, and how does the President’s
announcement impact this travel authorization?
Individual people-to-people travel is educational travel that: (i) does not involve
academic study pursuant to a degree program; and (ii) does not take place under the
auspices of an organization that is subject to U.S. jurisdiction that sponsors such
exchanges to promote people-to-people contact. The President instructed Treasury to
issue regulations that will end individual people-to-people travel. The announced
changes do not take effect until the new regulations are issued.

3. Will group people-to-people travel still be authorized?
Yes. Group people-to-people travel is educational travel not involving academic study
pursuant to a degree program that takes place under the auspices of an organization that is subject to U.S. jurisdiction that sponsors such exchanges to promote people-to-people
contact. Travelers utilizing this travel authorization must maintain a full-time schedule of educational exchange activities that are intended to enhance contact with the Cuban
people, support civil society in Cuba, or promote the Cuban people’s independence from
Cuban authorities, and that will result in meaningful interaction between the traveler and individuals in Cuba. An employee, consultant, or agent of the group must accompany
each group to ensure that each traveler maintains a full-time schedule of educational
exchange activities.

4. How do the changes announced by the President on June 16, 2017 affect individual
people-to-people travelers who have already begun making their travel
arrangements (such as purchasing flights, hotels, or rental cars)?
The announced changes do not take effect until OFAC issues new regulations. Provided
that the traveler has already completed at least one travel-related transaction (such as
purchasing a flight or reserving accommodation) prior to the President’s announcement
on June 16, 2017, all additional travel-related transactions for that trip, whether the trip
occurs before or after OFAC’s new regulations are issued, would also be authorized,
provided the travel-related transactions are consistent with OFAC’s regulations as of June
16, 2017.

5. How do the changes announced by the President on June 16, 2017 affect other
authorized travelers to Cuba whose travel arrangements may include direct
transactions with entities related to the Cuban military, intelligence, or security
services that may be implicated by the new Cuba policy?
The announced changes do not take effect until OFAC issues new regulations.
Consistent with the Administration’s interest in not negatively impacting Americans for
arranging lawful travel to Cuba, any travel-related arrangements that include direct
transactions with entities related to the Cuban military, intelligence, or security services
that may be implicated by the new Cuba policy will be permitted provided that those
travel arrangements were initiated prior to the issuance of the forthcoming regulations.

6. How do the changes announced by the President on June 16, 2017 affect companies subject to U.S. jurisdiction that are already engaged in the Cuban market and that may undertake direct transactions with entities related to the Cuban military, intelligence, or security services that may be implicated by the new Cuba policy?
The announced changes do not take effect until OFAC issues new regulations.
Consistent with the Administration’s interest in not negatively impacting American
businesses for engaging in lawful commercial opportunities, any Cuba-related
commercial engagement that includes direct transactions with entities related to the
Cuban military, intelligence, or security services that may be implicated by the new Cuba
policy will be permitted provided that those commercial engagements were in place prior to the issuance of the forthcoming regulations.

7. Does the new policy affect how persons subject to U.S jurisdiction may purchase
airline tickets for authorized travel to Cuba?
No. The new policy will not change how persons subject to U.S. jurisdiction traveling to
Cuba pursuant to the 12 categories of authorized travel may purchase their airline tickets.

8. Can I continue to send authorized remittances to Cuba?
Yes. The announced policy changes will not change the authorizations for sending
remittances to Cuba. Additionally, the announced changes include an exception that will
allow for transactions incidental to the sending, processing, and receipt of authorized
remittances to the extent they would otherwise be restricted by the new policy limiting
transactions with certain identified Cuban military, intelligence, or security services. As
a result, the restrictions on certain transactions in the new Cuba policy will not limit the
ability to send or receive authorized remittances.

9. How does the new policy impact other authorized travel to Cuba by persons subject to U.S. jurisdiction?
The new policy will not result in changes to the other (non-individual people-to-people)
authorizations for travel.  Following the issuance of OFAC’s regulatory changes, travel-related transactions with prohibited entities identified by the State Department generally will not be permitted.  Guidance will accompany the issuance of the new regulations.

10. How will the new policy impact existing OFAC specific licenses?
The forthcoming regulations will be prospective and thus will not affect existing
contracts and licenses.

11. How will U.S. companies know if their Cuban counterpart is affiliated with a
prohibited entity or sub-entity in Cuba?
The State Department will be publishing a list of entities with which direct transactions
generally will not be permitted. Guidance will accompany the issuance of the new
regulations. The announced changes do not take effect until the new regulations are
issued.

12. Is authorized travel by cruise ship or passenger vessel to Cuba impacted by the new Cuba policy?
Persons subject to U.S. jurisdiction will still be able to engage in authorized travel to
Cuba by cruise ship or passenger vessel.  Following the issuance of OFAC’s regulatory changes, travel-related transactions with prohibited entities identified by the State Department generally will not be permitted. Guidance will accompany the issuance of the new regulations.

For more information on the National Security Presidential Memorandum visit: https://www.whitehouse.gov/blog/2017/06/16/fact-sheet-cuba-policy.