Overview

The U.S. Office of Foreign Assets Control (OFAC) has imposed broad comprehensive sanctions against Cuba, as outlined in the Cuban Assets Control Regulations (31 CFR 515). These sanctions restrict certain academic collaborations and exchange of materials and equipment.

If your activities involve collaboration with Iranian residents or with individuals "ordinarily resident" in Cuba, travel to Cuba, or shipping any items to a Cuban entity or individual, you are required to contact the GVSU Office of Research Compliance and Integrity (ORCI) for consultation.

Who This Applies To

The regulations apply to “US persons.” That includes any US citizen, permanent resident alien, entity organized under the laws of the United States (including foreign branches), or any person in the United States.

Penalties

The penalties for engaging in restricted activities without the proper export control license can be severe, and individuals can be held personally liable. Both individuals and the University can face criminal and civil penalties if export control violations occur.

Travel to Cuba

Travel to Cuba for tourist activities is not allowed. However, travel to Cuba is allowed for the following reasons, provided certain additional conditions are met: 

• Professional research
• Educational activities
• Journalistic activities
• Family visits
• Official business of the US government, foreign governments and certain intergovernmental organizations
• Religious activities
• 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
• Certain authorized export transactions

**Effective 9/24/2020: Note this no longer includes travel to Cuba for the attendance at, or organization of, professional meetings or conferences. A specific export license must be obtained from the U.S. Office of Foreign Assets Control for conference attendance in Cuba.**

Note that each of these categories have specific conditions that must be met for the travel to be authorized. Don’t travel to Cuba without consulting the Office of Research Compliance and Integrity (ORCI)!

Travelers to Cuba must “self-certify” that they have met all of the OFAC requirements to travel without a license. Records of any travel-related transactions (tickets, receipts, etc.) must be kept for a minimum of five years following the date of travel. The traveler’s schedule must not include free time or recreation in excess of that consistent with a full-time schedule related to the authorized travel in Cuba.

Other Activities

Certain restrictions exist related to other activities involving Cuba as well. These activities include, but are not limited to, certain financial transactions (including paying for certain accommodations while in Cuba) and the importation and exportation of goods and services. You are required to consult with the ORCI prior to engaging in any activity involving Cuba.

For More Information

Please contact the Office of Research Compliance and Integrity ((616) 331-3197; [email protected]) to discuss any planned GVSU-related work involving Cuba. You are required to consult with the ORCI prior to engaging in any GVSU activity involving Cuba.