In a previous post, we outlined the updates to the OFAC general license which make it easier–though with hurdles, of course–to set up study abroad programs for U.S.-based students in Cuba. Because our consulting work involves educational programming, those are the parts of the general license (or “blanket license”) that we focussed on and will continue to focus on.
What is termed “People-to-People” education programing is, in many ways, the “easiest” route for U.S.-based organizations that do not have a license through OFAC to operate programs in Cuba (getting that license is not the easiest process, though we will cover it in future posts).
Essentially, the U.S.-based group travels to Cuba under the new general license and links up with the Cuban Tour Operator (a licensed tour operator, important note!) that is based in Cuba. Of course, the itinerary will have already been worked out and disseminated to the group of U.S.-based students who must be accompanied by a representative of the U.S. institution. The legality of the study period in Cuba is built around the Cuban Tour Operator’s license. The itinerary, then, is set in stone and, for that reason, some of the more alternative U.S.-based organizations might feel limited at times. But fear not: the Cuban Tour Operators are fantastic and we have worked with them closely in the past. (In a separate post, expect some “stories from the field” based on a 2012 Faculty Development Seminar).
That said, there are intermediaries between the would-be U.S.-based group (which is termed “sponsor”) and the Cuban Tour Operators. They have multiple names and are based all over the world. It is a fascinating system that resembles Cuban line formation and transportation-induced lexicon (“Último, detrás de quién vá, última persona para la veinte, dale caballeros levantén la mano po favo’, and so on and so on, until everyone seeks out shade in twenty different locations, all to miraculously–or not–join in perfect order when the bus arrives). Another one of our wind-like tangents… digressions… Whatever we should call them…
When you need technical questions answered, though, these satellite intermediaries need to go to the source: the licensed Cuban Tour Operator that they have partnership with. That is an important detail, especially as questions of “sponsorship” identity get confusing in the age of custom and faculty-led programming.
Indeed, when large U.S.-based study abroad providers organize educational travel packages to U.S.-based groups, who exactly is the “sponsor”? The group that will travel (a small prep school in Cambridge, Mass. for example), or the study abroad company? And then, in a age of authenticity, what exactly is the study abroad company doing if some of the Cuban Tour Operators must maintain somewhat fixed itineraries as per Cuban laws and policies? If the Cuban Tour Operator essentially creates and implements the educational trip for the “sponsor” (the U.S. group school), then what does the U.S. company do? Are they a sponsor? Do they become a sponsor by simply sending a representative of the company?
Obviously, we have many questions as our team has put together over 30 custom and faculty-led programs in Brazil for many U.S. universities through U.S.-based study abroad companies. One thing that would make sense to us, more observers in a post-1/26/16 general license moment, is to to answer ‘yes’ to many questions:
Yes, embedding student-centered approaches to even fixed Cuban Tour Operator itineraries is possible; Yes, having a role in shaping the itinerary with the Cuban Tour Operators is possible with strong relations and a track-record of success with those companies (and not always the satellite partners); Yes, there can be a productive dual-sponsorship between U.S.-based entities, a sending institution (“the sponsor”) and the organization that gives the program shape. We will continue to research and post on this topic while assembling this method of program development in partnership with all of the interested parties.