As the leader of a religious organization, can I organize a religious trip to Cuba for members of my organization?

Yes. You are required only to carry a letter on official letterhead that has been signed by a representative of the sponsoring US religious organization who has been designated to be the official responsible for that organization’s Cuba travel program. The religious travels to Cuba must consist of a full-time schedule of religious activities.

The following Frequently Asked Question is an extract from the latest Frequently Asked Questions published by the US Treasury Department Office of Foreign Assets Control, or OFAC.

705. Who is generally authorized to engage in travel-related transactions for “religious activities”?

Section 515.566 of the CACR contains a general license that authorizes, subject to conditions, travel-related transactions and other transactions that are directly incident to religious activities in Cuba. All persons subject to U.S. jurisdiction, including religious organizations located in the United States and members and staff of such organizations, are generally authorized to engage in travel-related transactions that are directly incident to engaging in religious activities in Cuba provided, among other things, that the travel must be for the purpose of engaging in a program of religious activities. In accordance with NSPM-5, OFAC amended this general license to exclude from the authorization direct financial transactions with entities and subentities identified on the State Department’s Cuba Restricted List. 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. The traveler’s schedule of activities must not include free time or recreation in excess of that consistent with a full-time schedule in Cuba. For a complete description of what this general license authorizes and the restrictions that apply, see 31 CFR § 515.566.