Activities Involving Cuba
Overview
University research and professional activities involving Cuba are subject to U.S. sanctions and export control requirements.
The specific requirements depend on the proposed activity, participating individuals and organizations, financial transactions, research assets or information being transferred, and other circumstances. Some activities may proceed under applicable U.S. Government authorizations, while others may require additional authorization or may be prohibited.
Activities involving Cuba may also be subject to federal sponsor requirements, research security considerations, disclosure requirements, research agreements, and other institutional requirements.
The Office of Research Security (ORS) assists faculty, staff, and students in identifying applicable requirements before engaging in University research or professional activities involving Cuba.
REQUEST A SANCTIONS/EXPORT CONTROL REVIEW
Contact ORS Before You
Contact ORS before you:
- Travel to Cuba for research, educational, professional, humanitarian, or other University-related activities.
- Establish or participate in a research collaboration with an individual or organization in Cuba.
- Conduct research, consulting, technical assistance, teaching, training, or other professional services involving Cuba.
- Organize or participate in a conference, meeting, workshop, seminar, or other professional activity in Cuba.
- Ship, hand-carry, or electronically transfer research equipment, materials, software, technology, technical information, research data, or other research assets to Cuba.
- Purchase goods or services from, or make payments to, individuals or organizations in Cuba.
- Enter into a research agreement or other University agreement involving a Cuban university, research institute, government agency, company, or other organization.
- Invite or host researchers, visitors, or collaborators from Cuba in connection with University research activities.
- Are uncertain whether sanctions, export control, research security, sponsor, or other institutional requirements apply to your proposed activity.
Key Considerations
University-related travel to Cuba is subject to U.S. sanctions requirements. Researchers should contact ORS before making travel arrangements.
ORS will review the purpose of the travel, anticipated activities, host organizations, itinerary, planned transactions, and research equipment or other research assets that will be taken to Cuba to identify applicable sanctions, export control, sponsor, and institutional requirements.
Travel arrangements should not be finalized until applicable requirements have been identified.
Research and professional activities involving individuals or organizations in Cuba are subject to U.S. sanctions and may also involve export control, sponsor, research security, disclosure, contractual, or other institutional requirements.
Activities may include:
- Collaborative or sponsored research
- Consulting or technical assistance
- Teaching or training
- Data or software sharing
- Material transfers
- Research agreements
- Conferences, meetings, and other professional activities
- Other research or scholarly activities
ORS reviews the proposed activity and participating organizations to identify applicable requirements before the activity begins.
Financial transactions involving Cuba are subject to U.S. sanctions requirements and may require review before commitments or payments are made.
Transactions may include:
- Registration or conference fees
- Lodging and travel expenses
- Reimbursements
- Purchases of goods or services
- Honoraria or other payments
- Research-related expenses
- Payments associated with agreements or collaborations
Researchers should consult ORS before making or committing to research-related payments involving Cuba. ORS will coordinate with the appropriate University offices, as needed, to identify applicable requirements.
Research equipment, materials, software, technology, technical information, and other research assets transferred to Cuba are subject to U.S. export control requirements.
Contact ORS before:
- Shipping research equipment or materials to Cuba.
- Hand-carrying University equipment, scientific instruments, or research materials to Cuba.
- Transferring software or source code.
- Sharing technology or technical information.
- Electronically transferring research information that may be subject to export control requirements.
- Transferring biological materials, chemicals, samples, prototypes, or other research assets.
- Providing research equipment or other items to collaborators in Cuba.
ORS will determine whether an export license, license exception, or other U.S. government authorization is required before the transfer occurs.
Research involving Cuba may also be subject to federal sponsor requirements, research agreements, disclosure requirements, University travel procedures, information protection requirements, or other institutional requirements.
Researchers should review applicable sponsor and project requirements before beginning an activity involving Cuba.
ORS assists researchers in identifying research security, export control, and sponsor requirements and coordinates with other University offices, as appropriate.
Related Guidance
| Related Guidance | Description |
|---|---|
| International Travel | Guidance for international travel involving research, teaching, field work, conferences, or other University activities. |
| International Collaborations | Guidance for planning, establishing, conducting, and managing research collaborations with international researchers, institutions, companies, and organizations. |
| Conferences, Professional Activities & External Appointments | Guidance for participating in conferences, meetings, seminars, workshops, professional societies, external appointments, teaching, lectures, and other scholarly activities involving international organizations or conducted outside the United States. |
| Foreign Sponsored Research | Guidance for proposing, conducting, and managing research funded or otherwise supported by foreign governments, universities, companies, foundations, or other foreign organizations. |
| International Transfers (Shipments, Hand-Carry & Electronic Transmissions) | Guidance for shipping, mailing, hand-carrying, or electronically transferring research equipment, materials, software, technology, technical information, or research information internationally. |
| Sharing Research Information | Guidance for sharing research information, data, software, technology, technical information, presentations, publications, or other research outputs with collaborators, sponsors, companies, government agencies, or other third parties. |
| Sponsor & Agreement Requirements | Guidance for reviewing and complying with research security, export control, information protection, publication, and other project-specific requirements contained in sponsor solicitations, award terms, and research agreements. |
| Restricted Entity Screening | Learn how organizations and individuals are screened against U.S. government restricted party and entity lists before certain research activities. |
| Sanctions & Embargo Programs | Guidance for understanding U.S. sanctions programs and conducting research activities involving sanctioned destinations. |
Frequently Asked Questions
Can I travel to Cuba for University research?
Possibly.
Certain research, educational, professional, and other activities may be authorized under U.S. sanctions regulations. However, the applicable requirements depend on the purpose and circumstances of the proposed travel.
Contact ORS before making travel arrangements so the proposed activity and related transactions can be reviewed.
Can I collaborate with a researcher or institution in Cuba?
Possibly.
Requirements depend on the participating individuals and organizations, proposed research activities, services or information being provided, financial transactions, and other circumstances.
ORS will review the proposed collaboration to identify applicable sanctions, export control, sponsor, research security, and institutional requirements.
Can I take a laptop or research equipment to Cuba?
Possibly.
University-owned laptops, scientific equipment, software, research materials, storage devices, and other items taken to Cuba are subject to U.S. export control requirements.
Contact ORS before traveling with University-owned or research-related equipment or other research assets.
Can I ship or send research materials to Cuba?
Possibly. Equipment, materials, software, technology, technical information, biological materials, chemicals, samples, and other research assets transferred to Cuba are subject to U.S. export control requirements.
Contact ORS before shipping, hand-carrying, or electronically transferring research assets to Cuba.
Can I make payments to individuals or organizations in Cuba?
Possibly. Financial transactions involving Cuba are subject to U.S. sanctions requirements. Restrictions may apply to payments, purchases, reimbursements, lodging, registration fees, honoraria, and other transactions.
Contact ORS before making or committing to research-related financial transactions involving Cuba.
Do virtual activities involving Cuba require review?
They may. Virtual collaborations, meetings, training, consulting, technical assistance, software sharing, data sharing, and other remote activities may involve U.S. sanctions or export control requirements even when no one travels to Cuba.
Contact ORS before providing services, software, technology, technical information, or other research resources remotely when you are uncertain whether restrictions apply.
Need Assistance?
Activities involving Cuba are subject to U.S. sanctions and export control requirements and may also involve research security, sponsor, financial, contractual, and other institutional requirements.
Contact the Office of Research Security before making University-related travel arrangements, entering into agreements, making or committing to payments, transferring research information or materials, providing services, or beginning research activities involving Cuba.
Early consultation helps identify applicable requirements and determine whether additional review or U.S. Government authorization is required before the proposed activity proceeds.