§515.574 covers activities of individuals, human rights organizations & NGO’s that promote independent activity intended to strengthen civil society in Cuba when travelers engage in a full-time schedule of activities (see above for definition of “full time”) that enhance contact with Cuban people, support civil society in Cuba, and result in meaningful interaction with individuals in Cuba. For compliance with the 515.574 GL, staying at hotels on the restricted entities list is prohibited. License category compliance is a result of engaging in full time activities per the license description.
“Example 1 to §515.574: An individual plans to travel to Cuba, stay in a room at a rented accommodation in a private Cuban residence (casa particular), eat at privately-owned Cuban restaurants (paladares), and shop at privately-owned stores run by self-employed Cubans (cuentapropista) during his or her four-day trip. While at the casa particular, the individual will have breakfast each morning with the Cuban host and engage with the Cuban host to learn about Cuban culture. The traveler will not lodge, or pay for lodging, at any property on the CPA List to the extent prohibited by § 515.210. In addition, the traveler will complete his or her full-time schedule by supporting Cuban entrepreneurs launching their privately-owned businesses. The traveler’s activities promote independent activity intended to strengthen civil society in Cuba. Because the individual’s qualifying activities are not limited to staying in a room at a rented accommodation in a private Cuban residence (casa particular), eating at privately-owned Cuban restaurants (paladares), and shopping at privately owned stores run by self-employed Cubans (cuentapropista) and the traveler maintains a full-time schedule that enhances contact with the Cuban people, supports civil society in Cuba, and promotes the Cuban people’s independence from Cuban authorities, and that results in meaningful interaction between the traveler and Cuban individuals, the individual’s travel qualifies for the general license.
Example 2 to §515.574: A group of friends plans to travel and maintain a full-time schedule throughout their trip by volunteering with a recognized non-governmental organization such as the Fundacion de Antonio Nuñez Jimenez to undertake environmental cleanup actions to support Cuba’s 100-year climate change plan Tarea Vida. In their free time, the travelers plan to rent bicycles to explore the streets of Havana and visit an art museum. The travelers will not lodge, or pay for lodging, at any property on the CPA List to the extent prohibited by §515.210. The travelers’ trip would qualify for the general license because the volunteer activities promote independent activity intended to strengthen civil society in Cuba and constitute a full-time schedule that enhances contact with the Cuban people and supports civil society in Cuba, and results in meaningful interaction between the travelers and individuals in Cuba.
Example 3 to §515.574: “An individual plans to travel to Cuba, rent a bicycle to explore the neighborhoods and beaches, and engage in brief exchanges with local beach vendors. The individual intends to stay at a hotel that does not appear on the Cuba Restricted List, and will not lodge, or pay for lodging, at any property on the CPA List to the extent prohibited by § 515.210. The traveler’s trip does not qualify for this general license because none of these activities promote independent activity intended to strengthen civil society in Cuba.”
Note to 515.574(a): Each person relying on the general authorization in this paragraph must retain specific records related to the authorized travel transactions. See §501.601 and §501.602 of this chapter for applicable recordkeeping and reporting requirements.”
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