Saturday, April 30, 2011

IES Abroad to Open Cuba Center for Study Abroad

In response to the recent updates in the U.S. government’s regulations regarding studying abroad in Cuba, the IES Abroad Board of Directors has approved the opening of a center in Havana, Cuba, offering students from IES Abroad’s 185-school academic consortium an exciting new location for international study.

As a result of this approval, IES Abroad has now entered into discussions with several American and Cuban institutions of higher education, with the objective of developing academic partnerships to provide study abroad programs for students interested in semester, full year, and faculty-led short term programs. 

Academic programs to be offered in Cuba are currently in development, and locations for the IES Abroad student center and student housing options are currently being identified.

For students interested in studying abroad, Cuba offers a unique culture and history, proximity to the United States, low costs, and an exciting location to meet the growing demand for Spanish-language learning.

“We are pleased to be developing a new center for our consortium in a country where students will have the opportunity to study a unique culture, an evolving political environment, and a developing economy,” says Michael Steinberg, IES Abroad executive vice president of Academic Programs. “A center in Cuba will incorporate all of the IES Abroad program components, including academic rigor, cultural immersion, language-learning, experiential opportunities, and unmatched student services.”

Friday, April 22, 2011

Preliminary Analysis of OFAC Travel Guidelines Issued April 19, 2011

The guidelines for general licenses implement a real step forward, confirming the ease of undertaking student and religious travel (for which most Americans are eligible). 

Higher education and religious organizations are given a clear path for purposeful travel, subject only to internal procedural requirements.

“General licenses constitute blanket authorization for those transactions set forth in the relevant regulation.  No further permission from OFAC is required to engage in transactions covered by a general license.”  (p 5)

The guidelines semi-suggested that the meaning of "religious activities" was subject to foreign policy, but finally provided a bigger more Constitutionally legitimate tent

“Activities that are consistent with U.S. foreign policy include, but are not limited to, attendance at religious services as well as activities that contribute to the development of a Cuban counterparts religious or institutional development...”     (p 4)

In a backhanded way, the guidelines indicate that religiously oriented educational travel qualifies for a self-authorized general license if put together and led by a religious organization:

“Not Licensed

Example 2: An organization that specializes in organizing heritage tours for persons of a particular denomination wishes to take interested practitioners of that faith on a trip to Cuba to visit historical sites and museums as well as existing communities of that denomination in Cuba.  The proposed travel does not fall within the scope of the general license inasmuch as the organization putting together and leading the tour is not a religious organization.

Example 3: A group that seeks to promote interfaith understanding wishes to take an inter-denominational group to Cuba to participate in religious activities ranging from Catholic mass to Santeria. The proposed travel does not fall within the scope of the general license inasmuch as the group organizing and leading the tour is not a religious organization.”  (p 27)

Unfortunately, the many more pages devoted to specific licenses reflect a control rather than a facilitation attitude inconsistent with the goal of purposeful travel.  The President's January 14th announcement created the problem by unnecessarily requiring specific licenses for many categories of travel and leaving in charge an agency whose primary mission is to police the financial side of national security. 

The guidelines are unabashed that the potential for politicized and arbitrary negative judgments is inherent the process

"Meeting all of the relevant specific licensing criteria in a given section does not guarantee that a specific license will be issued, as foreign policy considerations and additional factors may be considered by OFAC in making its licensing determinations....specific licenses are not granted as a matter of right."  (p 4)

The real question about what the guidelines actually mean remains unanswered until OFAC starts acting on the back-log of applications from groups that were licensed for people to people travel under the Clinton Administration.  The brief section in the guidelines appears reasonable with a potentially large positive impact.  However do OFAC and the State Department have the number of staff, real knowledge about Cuba and enough familiarity with US not-for-profits to make fair, reasonable and timely evaluations of a wide range of prospective programs?

“OFAC may issue a specific license to an organization that sponsors and organizes programs to promote people-to-people contact authorizing the organization and
individuals traveling under its auspices to engage in educational exchanges not involving academic study pursuant to a degree program.  In general, licenses issued pursuant to this policy will be valid for one year and will contain no limitation on the number of trips that can be taken.”  (p 22)  

The guidelines recommend that organizations

"submit an application to OFAC no later than 45 days prior to the proposed date of departure". (p 7)

Effective trips cannot be planned and promoted without at least two or three months of lead time.  OFAC will frustrate travel this summer if it waits another month to authorize pending and new applications.

OFAC practice requires close independent monitoring.  On what grounds, for example, did it deny a license for Irish American traditional musicians to participate in the Celtic Festival in Cuba when the guidelines give this example of what is OK for performances?

“Potentially licensable under current policy

Example 1: A musical artist wishes to travel to Cuba to participate in a series of public performances with Cuban artists whose venues will be open to the Cuban public and whose profits after costs will be donated to an independent non-governmental organization in Cuba.”  (pp 31-32)

The contradictions that arise from a narrow politicized interpretation of purposeful travel are most flagrant in Humanitarian Projects.  Charity is OK; collegiality is not.

“Potentially licensable under current policy

Example 2: A U.S. group of medical professionals that specializes in the treatment of HIV/AIDS wishes to support a community in Cuba by providing the latest techniques and literature in HIV/AIDS education and prevention directly to the Cuban people.

Normally not licensable under current policy

Example 4: A group of doctors wish to provide medical training to Cuban healthcare professionals.  Travel-related transactions in connection with providing medical training of professionals would not be licensed under this licensing policy.”  (p 37)

Groups that deliver token humanitarian donations embody a double edge of patronizing and generosity, but making them “not licensable” is actually a step backward from current practice.  

Example 2: A U.S. humanitarian organization wants a license to travel to Cuba to provide humanitarian aid and will solicit participation by any interested persons under such a license.  The travelers would not be affiliated with the organization except for the purpose of travel to Cuba under the license and the travelers will purchase the humanitarian aid that will be donated.”  (p 37)

The perverseness of using people-to-people engagement as an anti-government tool to foster system change is illustrated by another proffered instance of illicit humanitarianism:

“Example 3: A volunteer organization seeks a license to assist with a school construction project in Cuba.  Since most schools in Cuba are government run, this project normally would not be licensed.  (p 37)

The head of an important international aid program, wrote

“Guess what?. The guidelines under Section IX (pp 35-37) tighten up who we can take to Cuba and what their relationship with our organization must be---e.g. one time travelers for a humanitarian aid mission to a pediatric hospital are not necessarily OK under this category.  If I recruit a volunteer with credentials but he/she is not staff or a board member and is only there for the trip, they may not be licensable. There is also the little matter of the US government wanting way more info on whom we meet with from the Cuban government and why everyone is turned into an intelligence agent”

Hidden away in Section XII, “Licensed Exportations” is this complete non-sequitur

“Normally not licensable under current policy

Example 1: City officials wish to travel to Cuba to establish a sister city relationship with government officials of a Cuban city or province. Travel to Cuba for this purpose is not within the scope of current licensing policy.” (p 47)

What could be more conducive to people to people relationships than a sister city partnership?  The fundamental trust building goal of exchanges is frustrated by the ideology of system change.

OFAC did keep in effect the punitive rule (seldom enforced by US Customs) against bringing back anything except informational materials from Cuba:

"authorized travelers are prohibited from importing into the United States any merchandise purchased or otherwise acquired in Cuba, including but not limited to cigars and alcohol" (p 8)

Ironically informational materials are likely to be given or sold by state sources while handicraft souvenirs are usually produced by private artisans.

Still in place is Bush language which bars use of a general license for international conferences organized by Cubans and by groups based in the US.  However, OFAC indirectly offers a possible path for authorized American organized events:

"A professional organization headquartered in the United States cannot organize or hold a meeting or conference in Cuba without a specific license issued by OFAC."  (p 16)

Presumably the kind of meeting or conference contemplated is a workshop

“open for attendance, and in relevant situations, participation by the Cuban public” (p 30)

It is stated clearly that authorized travelers can use third country agents and tour operators to book travel, accommodations and programs, thus doubly disadvantaging US companies that are not among the 240 licensed Travel Service Providers (3/4th of which are located in Florida).

"Authorized travelers wishing to make their own travel arrangements without the use of a TSP must handle those arrangements directly with travel service providers that are located outside the United States and that are not subject to U.S. jurisdiction."  (p 8)

One of the more bizarre provisions is the need to protect people to people groups from spending too much time with the power structure, unless “individuals or entities acting for or on behalf of” is meant to preclude engagement with most of Cuba’s organized civil society, by certifying:

 “the predominant portion of the activities to be engaged in by individuals traveling under your program(s) will not be with individuals or entities acting for or on behalf of a prohibited official of the Government of Cuba, as defined in 31 C.F.R. 515.337, or a prohibited member of the Cuban Communist Party, as defined in 31 C.F.R. 515.338.” (p 23)

In truth the people and institutions specified are the most influential sectors of daily Cuban life, and among those with whom the Americans need to develop mutual understanding and relationships: 

The term prohibited official of the Government of Cuba is defined in 31 CFR 515.337 to mean Ministers and Vice-ministers, members of the Council of State and the Council of Ministers; members and employees of the National Assembly of Peoples Power; members of any provincial assembly; local sector chiefs of the Committees for the Defense of the Revolution; Director Generals and sub-Director Generals and higher of all Cuban ministries and state agencies; employees of the Ministry of the Interior (MININT); employees of the Ministry of Defense (MINFAR); secretaries and first secretaries of the Confederation of Labor of Cuba (CTC) and its component unions; chief editors, editors, and deputy editors of Cuban state-run media organizations and programs, including newspapers, television, and radio; and members and employees of the Supreme Court (Tribuno Supremo Nacional). The term prohibited member of the Cuban Communist Party is defined in 31 CFR 515.338 to mean members of the Politburo, the Central Committee, Department Heads of the Central Committee, employees of the Central Committee, and secretaries and first secretaries of the provincial Party central committees.

Bottom line, the guidelines are a step forward to implement the new regulations, but an oddly over-cautious and out of sync response to a neighbor that has launched itself on a path of major social and economic reform.
--John McAuliff, Fund for Reconciliation and Development, 4/22/11

Thursday, April 21, 2011

Cuba’s Approved Travel Insurance Company List

HAVANA TIMES, Nov. 22 — Cuba’s insurance authorities have published a complete list of the foreign travel policy sellers that are valid for visiting the island. Here is an explanation on how to explore the list:

A traveler can either take out an insurance policy in one’s home country before departure, or can choose to take out a policy of insurance and assistance from a Cuban insurance company (Asistur S.A.) upon arrival at the airport, port or marina.Since May 1, 2010 it has been mandatory that all travelers, foreign and Cubans, living abroad must have a medical insurance policy when visiting Cuba – and this policy must have coverage in Cuba.
However, residents in the United States traveling to Cuba will have to take out their insurance policy in their home country of departure from Cuban insurance companies through agencies associated with Havanatur-Celimar, as U.S. insurance companies do not provide coverage within Cuba.
A list of overseas medical insurance companies that provide coverage in Cuba is found on the website ofAsistur S.A. at The site exists in both Spanish and English.
When you open the main page, on the left hand side under La Organización (The Business), click on ASISTUR es corresponsal para la asistencia de las compañías… (ASISTUR works as correspondent for the companies listed below…), then click on different letters of the alphabet for a list of international insurance companies with which Cuba has relations. It’s an alphabetical list of companies rather than an alphabetical list of countries.Note: there is also a message that says Pero otros seguros son válidos también… (But other travel insurances are valid as well…), suggesting that the list changes as insurance policies change.
As for Asistur S.A. itself, since 1991 it has been the leading company in Cuba specializing in rendering assistance services to visitors. With a wide network of providers around the country and an Alarm Centre available 24 hours a day, seven days a week, Asistur S.A. acts as the corresponding insurance broker for international insurance companies. Information about the benefits they provide and what they cost are found on their website.
The telephone numbers for Asistur S.A. in Havana are listed below – and their website has listings for their offices located elsewhere in the country. Similarly, you can also write them directly at their email addresses listed below.
Asistur S.A.
Alarm Central 24 hours
Tel (53 7) 866-8527, 866-8339, 867-1315
Fax (53 7) 8-66-80

Tuesday, April 19, 2011

Dominican University Sends First Short Term Student Group

Dominican University will be the first university in the country to send students to Cuba on a short-term program since President Barack Obama lifted travel restrictions to the country in January. Led by Dr. Christina Perez, associate professor of sociology, 23 students and faculty will leave on May 13 and return June 3. During their three-week trip, they will study the culture, history and politics of the country while visiting the capital city of Havana; Baracoa, the northeastern city where Christopher Columbus first landed; and Santiago de Cuba, a 500-year-old city which played a central role in the Cuban Revolution.

Dominican University was able to quickly organize the trip following President Obama’s announcement on January 14 because of Dr. Perez’ long-term relationship with the University of Havana. She started planning the trip in 2009 but was stymied by the American government’s travel ban. Perez’s academic research has focused on Cuba for the past decade and she is an active participant in the Cuba section of the Latin American Studies Association. Last month she participated in an international symposium on Cuba 

sponsored by the City University of New York. In addition, she once worked at the University of Havana coordinating a study abroad program for US students visiting Cuba.

“Dominican truly values global citizenship and intercultural learning,” said Perez. “One way that we can create a more just and peaceful world is by having dialogue with people outside our borders. I want Dominican students to really learn about the country from the inside out—to be able to see things that a tourist wouldn’t have the opportunity to see.”

While in Cuba, the students will learn about the country’s pre- and post-colonial and revolutionary history, contemporary political and economic systems, and social institutions such as schools, hospitals and agricultural cooperatives. They will also experience Cuba’s rich cultural heritage through visits to churches, art galleries, museums and music venues.
Highlights of the trip will include visits to San Juan Hill, where Teddy Roosevelt led US troops in a famous battle during the Spanish-American War; the home of Diego Velasquez, the Spanish conquistador who served as the first governor of the Spanish colony; the grave of Jost Marti, the Cuban poet and independence fighter; the Martin Luther King Jr. Memorial Center in Havana; and Hemingway’s home, Finca Vigia.

Students will receive six college credits for work leading up to the trip as well as a comprehensive paper following the trip. Dominican is joining institutions such as Harvard, Princeton and Sarah Lawrence in sending students to Cuba this year.

Jessica Mackinnon
(708) 524-6452