§ 515.416 - Professional research and similar activities.

(a) Section 515.560(b) sets forth the criteria on which specific licenses for transactions related to travel to, from, and within Cuba may be issued for persons engaging in professional research and similar activities of a noncommercial, academic nature. Persons traveling to Cuba to engage in professional research must engage in a full work schedule in Cuba, and there must be a substantial likelihood of public dissemination of the product of their research. No transactions related to tourist or recreational travel within Cuba are authorized in connection with professional research, except those that are consistent with a full schedule of research activities.

(1) Persons are considered to be engaging in professional research for purposes of this section:

(i) If they are full-time professionals who travel to Cuba to do research in their professional areas and their research is specifically related to Cuba; or

(ii) If they are acting on behalf of an organization with an established interest in international relations to collect information related to Cuba.

(2) Similar activities include attendance by professionals with an established interest in Cuba at professional meetings where research on Cuba is shared, and travel for noncommercial research purposes specifically related to Cuba by persons who are working to qualify themselves academically as professionals (e.g., certain graduate degree candidates). Study visits to Cuba in connection with pre-college or undergraduate college course work are not within the scope of the term professional research and similar activities.

(b) Categories of travel which do not qualify as professional research or similar activities and for which specific license requests will be denied include recreational travel; tourist travel; travel in pursuit of a hobby; general study tours; general orientation visits; student class field trips; youth camps; research for personal satisfaction only; travel by fishing or bird-watching groups and similar affinity groups; and any travel for an authorized research purpose, if the schedule of activities includes free time, travel, or recreation in excess of that consistent with a full work schedule of professional research and similar activities.

(c) A group does not fall within the scope of the term professional research and similar activities merely because some members of the group could qualify individually for specific licensing under this category. For example, a specific license authorizing travel-related transactions by a fish biologist who travels to Cuba to engage in professional research does not authorize other persons who might travel with the fish biologist but whose principal purpose in travel is to engage in recreational or trophy fishing. The fact that such persons may engage in certain activities with, or under the direction of, the professional fish biologist, such as measuring or recording facts about their catch, does not bring these individuals’ activities within the scope of professional research and similar activities.

(d) A person will not qualify as engaging in professional research or similar activities merely because that person is a professional who plans to travel to Cuba. For example, a professor of history interested in traveling to Cuba for the principal purpose of learning or practicing Spanish or attending general purpose lectures devoted to Cuban culture and contemporary life would not qualify for a specific license. A doctoral candidate in economics traveling to Cuba to undertake research for a dissertation on the Cuban economy may qualify for a specific license for activities directly related to the research, but would not be authorized to stay an extra week in Cuba in order to attend a seminar on Cuban arts and crafts.