News and Updates
OFAC Sanctions and Cuba:
Effective September 30, 2026, OFAC amended § 515.564 to eliminate the authorization
related to the attendance at, or organization of, professional meetings or conferences
in Cuba. Persons subject to U.S. jurisdiction are no longer authorized to attend or
organize professional meetings or conferences in Cuba. OFAC is replacing that authorization
with a limited wind down authorization for persons subject to U.S. jurisdiction who
were in Cuba on September 30, 2026 pursuant to the former professional meetings authorization
to engage in travel-related and other previously authorized transactions through October
30, 2026, provided they depart Cuba by October 30, 2026. In addition, OFAC is also
authorizing persons to terminate and obtain refunds for travel and related transactions
for trips consistent with the former professional meetings authorization until October
30, 2026.
How does the September 30, 2026 amendment to the Cuban Assets Control Regulations
(CACR) affect educational travel to Cuba by persons subject to U.S. jurisdiction?
Effective September 30, 2026, OFAC narrowed the authorization for persons subject
to U.S. jurisdiction, including U.S. academic institutions and their faculty, staff,
and students, to engage in certain education-related transactions involving Cuba.
Persons subject to U.S. jurisdiction that wish to engage in educational activities,
including travel-related transactions, involving Cuba must now fit within one of these
categories:
Educational Activities by Accredited U.S. Undergraduate or Graduate-Degree Granting Institutions: 31 CFR § 515.565(a)(1) authorizes accredited U.S. undergraduate or graduate-degree granting institutions, their students, and full time permanent employees to engage in certain educational activities, such as noncommercial research in Cuba specifically related to Cuba and for the purpose of obtaining a graduate degree, under the auspices of the academic institution without accompaniment by a representative from a sponsoring organization.
Educational Activities by Other Institutions: § 515.565(a)(2) authorizes certain educational activities not authorized under § 515.565(a)(1),
such as certain educational exchanges sponsored by Cuban or U.S. secondary schools,
provided that the activity takes places under the auspices of an organization subject
to U.S. jurisdiction and that all travelers are accompanied by a representative of
the sponsoring organization.
Additionally, OFAC removed the previous authorization at § 515.565(b) for group people-to-people
educational travel.
OFAC replaced these education-related authorizations with "grandfathering" provisions
authorizing certain educational travel and group people-to-people educational travel
that previously was authorized under § 515.565(a) and § 515.565(b), respectively,
where the traveler has already completed at least one travel-related transaction (such
as purchasing a flight or reserving accommodation) prior to September 30, 2026.
"Dear Colleague" Letter:
On July 8, 2026, the U.S. National Science (NSF) issued a "Dear Colleague" letter, notifying the research community of a forthcoming policy prohibiting NSF funds from being expended on collaboration with entities on U.S. restricted entities parties lists. A link to the letter can be found here. Appendix A provides the U.S Proscribed Party Lists, which should be reviewed before submitting proposals. Although the policy is scheduled for full implementation in FY2027, NSF has already begun incorporating these restrictions into certain award and proposal review processes.
BioSecure Act:
The BIOSECURE Act, enacted on December 18, 2025, will phase restrictions that prevent federal funding recipients from using biotechnology equipment or services from “biotechnology companies of concern” in in the performance of federal contracts or grants.