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The twelve Cuba travel categories in 31 C.F.R. § 515.560(a) still exist, but OFAC’s September 30, 2026 amendments narrowed how they work. Group people-to-people educational travel and the general license for professional meetings in Cuba are gone. Most educational trips now need a sponsoring U.S. organization, and tourist travel remains prohibited.
What Changed in the Cuba Travel Categories on September 30, 2026
On September 29, 2026, the Office of Foreign Assets Control (OFAC) announced a package of Cuba measures. They took effect the next day. First, OFAC amended the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515, in a rule published at 91 Fed. Reg. 61741. Second, it issued new Cuba Sanctions Regulations at 31 C.F.R. part 516 to implement Executive Order 14404. Third, it released five new FAQs (1271 through 1275) and updated 29 others. It also published an alert titled “Expanded Sanctions Against Cuba.” The details appear in OFAC’s September 29 announcement.
The CACR rule implements National Security Presidential Memorandum-5, which the President reissued on June 30, 2025. The rule’s own summary lists three main changes. In OFAC’s words, it “adds a prohibition on indirect financial transactions with entities or subentities on the Cuba Restricted List.” It also removes the authorization for “U-Turn” transactions. Finally, it removes the authorizations for “group people-to-people travel and professional meetings in Cuba.” OFAC’s previous CACR amendment, on May 29, 2024, had broadened several of these authorizations. In contrast, the 2026 rule moves in the opposite direction.
For Miami businesses, families, universities, and banks, the practical question is simple. Which trips and payments remain authorized, and which now require a specific license? This article walks through the Cuba travel categories and the related banking changes, section by section.
The Twelve Categories of Authorized Travel to Cuba
Authorized travel to Cuba has never been open-ended for persons subject to U.S. jurisdiction. Instead, the regulations authorize travel-related transactions only for twelve activities. Each one works through a general license or a specific license issued case by case. The list of Cuba travel categories in 31 C.F.R. § 515.560 did not change on September 30, 2026. However, the general licenses behind several categories did.
Family visits (§ 515.561)
Official business of the U.S. government, foreign governments, and certain intergovernmental organizations (§ 515.562)
Journalistic activity (§ 515.563)
Professional research and professional meetings (§ 515.564)
Educational activities (§ 515.565)
Religious activities (§ 515.566)
Public performances, clinics, workshops, athletic and other competitions, and exhibitions (§ 515.567)
Support for the Cuban people (§ 515.574)
Humanitarian projects (§ 515.575)
Activities of private foundations or research or educational institutes (§ 515.576)
Exportation, importation, or transmission of information or informational materials (§ 515.545)
Certain authorized export transactions (§§ 515.533 and 515.559)
Two baseline rules still apply to every category. Section 515.560(f) states that nothing in the section authorizes tourist travel. Moreover, every traveler who relies on a general license must keep records of the trip under OFAC’s recordkeeping rules in part 501. Since September 30, 2026, most travel general licenses also exclude indirect financial transactions with Cuba Restricted List entities, not just direct ones. OFAC left a few general licenses outside that prohibition under the exceptions in NSPM-5.
Professional Meetings in Cuba: General License Ended
Before the amendment, § 515.564(a)(2) let persons subject to U.S. jurisdiction attend or organize professional meetings and conferences in Havana or elsewhere in Cuba under a general license. That authorization no longer exists. OFAC replaced it with a narrow wind-down license. Travelers who were already in Cuba on September 30, 2026 for a professional meeting may finish the trip. However, they must depart by October 30, 2026. Likewise, anyone who booked such a trip may cancel and obtain refunds through October 30, 2026.
The professional research general license in § 515.564(a)(1) survives. The research must relate directly to the traveler’s profession, professional background, or area of expertise. In addition, the schedule may not include more free time than a full-time research schedule allows. Section 515.564(e) confirms that OFAC may still issue specific licenses case by case. Those licenses can cover professional research outside the general license or professional meetings that relate to otherwise authorized activities. As a result, a conference trip is now a licensing question rather than a general-license checkbox.
People-to-People Travel and Educational Trips
Group people-to-people educational travel under § 515.565(b) has ended. OFAC kept only a grandfathering provision for people to people travel. A traveler may still complete such a trip in one situation. He or she must have finished at least one travel-related transaction for that specific trip, such as buying a flight or reserving accommodation, before September 30, 2026. Otherwise, people-to-people travel is no longer authorized, and tour operators cannot sell new group tours under that category.
Educational activities now split into two tracks. Under § 515.565(a)(1), accredited U.S. undergraduate or graduate degree-granting institutions may act without an escort. The same applies to their enrolled students and full-time permanent employees working under the institution’s auspices. Covered activities include a structured program in Cuba of at least ten weeks. They also include noncommercial academic research for a graduate degree and a formal course of study at a Cuban institution accepted for credit. Under § 515.565(a)(2), other organizations may sponsor educational activities only under stricter conditions. The travel must take place under the auspices of a U.S. organization, and a representative of that organization must accompany the travelers. A representative traveling alone may instead carry a letter from the sponsoring organization. FAQ 1274 explains these tracks. Finally, § 515.565(c) grandfathers educational trips with a transaction completed before September 30, 2026.
Banking Changes That Travelers and Businesses Will Feel
The rule also rewrote § 515.584, which governs financial transactions involving Cuba. Three changes matter most. First, OFAC removed the “U-turn” general license in § 515.584(d). Under that license, banks subject to U.S. jurisdiction could process funds transfers in which Cuba or a Cuban national had an interest. The transfers had to begin and end outside the United States between non-U.S. parties. Now banks are authorized to reject those transfers rather than block them. OFAC also removed the related unblocking authorization in § 515.584(e).
Second, OFAC rescinded § 515.584(h)(2). That provision had allowed banks to open accounts solely in the name of a Cuban independent private sector entrepreneur. According to FAQ 1273, banks must now block those funds and accounts and report them to OFAC, unless OFAC separately authorizes otherwise. Unblocking requires a specific license. Account holders who face a frozen account should read our explanation of how blocked funds are released. The license process follows a similar path.
Third, § 515.584(g) authorizes the processing of certain U.S. dollar instruments presented indirectly by Cuban financial institutions. That authorization now excludes direct or indirect financial transactions with Cuba Restricted List entities. Consequently, compliance teams should rescreen their Cuba-related payment flows against the current list. These banking limits apply regardless of which Cuba travel categories a traveler uses.
Cuba Restricted List: Indirect Transactions Now Prohibited
Section 515.209 previously barred only direct financial transactions with entities on the State Department’s Cuba Restricted List. The amended section now also prohibits indirect financial transactions. Under the new definitions, a direct transaction means acting as the originator or ultimate beneficiary of a funds transfer with a listed entity. An indirect transaction means taking part in such a transfer in another role, for example as an intermediary bank. Wire transfers, credit cards, checks, and cash payments all count.
OFAC also added an anti-evasion clause in § 515.201(c). It covers transactions that have the purpose or effect of evading these restrictions. Nevertheless, two exceptions remain in § 515.209(b) and (c). Travel-related transactions initiated before an entity was listed stay permitted. So do commercial engagements that were in place before the listing. Finally, the amended section broadens the criteria for adding entities tied to the Cuban military, intelligence, or security services. For travelers, the travel general licenses already exclude these Cuba Restricted List payments, whatever category they rely on.
Executive Order 14404 and the New Cuba Sanctions Regulations
The second rule published on September 30, 2026 added the Cuba Sanctions Regulations, 31 C.F.R. part 516. They implement Executive Order 14404 of May 1, 2026. That order relies on the national emergency declared in Executive Order 14380 earlier in 2026. It authorizes blocking sanctions on foreign persons who operate in Cuba’s energy, defense, metals and mining, financial services, or security sectors. It also reaches persons owned or controlled by the Cuban government and those who materially support blocked persons. Senior officials, persons responsible for serious human rights abuse or corruption related to Cuba, and adult family members of designated persons are covered as well.
Two features deserve attention. Section 4 of the order lets Treasury sanction foreign financial institutions that conduct or facilitate significant transactions for blocked persons. Meanwhile, section 2(b) preserves the validity of licenses issued under the CACR. OFAC’s General License 1 of May 7, 2026 goes further. It authorizes transactions that the order would otherwise prohibit whenever the CACR already authorizes or exempts them. Certain family remittances and deliveries of food and medicine are the main examples. OFAC describes the interaction between the two programs in FAQ 1252 and in its alert on expanded Cuba sanctions. OFAC has also said that part 516 is abbreviated for now and that fuller regulations will follow. Neither the order nor part 516 changes the Cuba travel categories themselves; those live in the CACR.
What This Means for South Florida
Miami sits at the center of this change. Charter operators and travel agencies that sold conference packages or group tours need to review every booking made before September 30, 2026 and keep the proof. Trips sold after that date must fit a surviving category, and most will require documentation from a sponsoring organization or a specific license.
Banks and money services businesses face a different list. They must stop processing U-turn transfers, identify accounts opened for Cuban independent entrepreneurs, block them, and file reports. Correspondent banking teams should also map intermediary exposure to Cuba Restricted List entities, because indirect participation now counts.
Universities and nonprofits remain able to operate, but under the older sponsored-and-escorted model. Program directors should re-paper letters for individual travelers and confirm that each itinerary tracks a licensed activity rather than recreation. For educational travel, authorized travel to Cuba now follows the requirements that applied on January 27, 2011.
Compliance Steps for Cuba Travel Authorizations and Payments
Because the amendments took effect immediately, our sanctions and licensing practice suggests a short review for anyone with Cuba exposure:
Match every planned trip, including packaged tours, to one of the twelve Cuba travel categories and confirm that a general license still covers it.
Cancel or relicense professional-meeting travel; the refund window closes on October 30, 2026.
Document any grandfathered trip with proof of a transaction completed before September 30, 2026.
For educational travel, confirm the sponsoring organization, the accompanying representative, or the required institutional letter.
Rescreen payment flows and counterparties against the Cuba Restricted List, including intermediary roles.
Banks should identify accounts held by Cuban independent entrepreneurs, block them, and file the required reports.
Keep travel and transaction records under part 501.
Consider a specific license application for activity that no longer fits a general license.
If a past transaction now looks problematic, evaluate a voluntary self-disclosure to OFAC before the issue surfaces another way.
Frequently Asked Questions
All twelve categories in 31 C.F.R. § 515.560(a) remain on the books. They include family visits, journalism, religious activities, humanitarian projects, and support for the Cuban people. However, OFAC removed the general licenses for group people-to-people travel and for professional meetings in Cuba on September 30, 2026. Tourist travel remains prohibited.
Group people-to-people educational travel is no longer authorized by general license. The only exception is a grandfathered trip. The traveler must have completed at least one travel-related transaction, such as a flight purchase, before September 30, 2026.
Not under a general license. OFAC eliminated the professional-meetings authorization. It allowed a wind-down only for travelers who were in Cuba on September 30, 2026, and they must leave by October 30, 2026. Attendance at a Havana conference now requires a specific license under § 515.564(e), which OFAC considers case by case.
OFAC rescinded the authorization for banks to maintain accounts solely in the name of a Cuban independent private sector entrepreneur. Banks must block the funds and report them to OFAC unless separately authorized. The account holder or bank will need a specific license to unblock the money.
Family visits remain an authorized category under § 515.561. The September 30, 2026 rule revised that section mainly to exclude indirect financial transactions with Cuba Restricted List entities. The remittance general license in § 515.570 was not among the provisions OFAC listed as amended in FAQ 1271.
Conclusion
The Cuba travel categories survived September 30, 2026, but the room inside them shrank. Conference travel moved from general license to specific license. People-to-people tours ended except for grandfathered bookings, and educational travel returned to a sponsored, escorted model. Meanwhile, the banking amendments and the new part 516 regulations raise the stakes for intermediaries and foreign financial institutions. In short, anyone touching Cuba should re-map their activity to the current rules before acting.
Transnational Matters PLLC advises individuals, companies, and financial institutions in Miami and abroad on OFAC licensing, blocked funds, and sanctions compliance. To discuss how the new rules affect your travel or transactions, contact our team to schedule a consultation.
