SolePictures, LLC

West Halifax, VT 05358

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CUBA SPECIFIC POLICIES
PLEASE READ CAREFULLY

SolePictures LLC is authorized to provide photography workshops in Cuba under a general license for people-to-people travel pursuant to 31 CFR §515.565 (b) of the Cuban Assets Control Regulations (CACR). A general license authorizes persons subject to U.S.

 

jurisdiction, including travel agents and tour group operators, to provide travel services in connection with authorized travel without the need for specific licenses from the Office of Foreign Assets Control (OFAC).  For a complete description of what these general licenses authorize and the restrictions that apply, see 31 CFR § 515.572(a) (1).

The general license for people-to-people travel authorizes the travel-related transactions set forth in § 515.560(c) and such additional transactions as are directly incident to educational exchanges not involving academic study pursuant, provided that: (1) The exchanges take place under the auspices of an organization subject to U.S. jurisdiction and that sponsors people-to-people contact; (2) Travel-related transactions are for engaging in a full-time schedule of activities to enhance contact with the Cuban people, support civil society in Cuba, or promote the Cuban people’s independence; (3) Each traveler has a full-time schedule of educational exchange activities of interaction between the traveler and individuals in Cuba; (4) An agent of the sponsoring organization accompanies each group traveling to Cuba to ensure the compliance of each traveler with the regulations; (5) The predominant portion of the activities engaged in is not with individuals or entities acting for or on behalf of a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party.  

No further permission from OFAC is required to engage in transactions by a person who meets all criteria in a general license. Individuals wishing to engage in activities that may fall within the scope of a general license should review the relevant general licenses contained in the CACR to determine whether their travel-related transactions are covered by such general licenses. For more information on the CACR, please refer to the Frequently Asked Questions related to Cuba on the U.S. Department of the Treasury’s Site. OFAC is responsible for administering the U.S. regulations concerning Cuba. Information about these General Licenses and their requirements can be found on the official website for the U.S. Treasury Department’s OFAC:

 

https://www.treasury.gov/resource-center/sanctions/Programs/Pages/cuba.aspx