In previous posts on Cuba (see our Study Abroad Consulting category), we described People-to-People travel to Cuba through Cuban Tour Operators. In the lexical labyrinth, at least based on what we have seen, these Cuban-based operations are the entities that provide the Cuban license, making your educational travel legal on the island. Your U.S.-based study abroad company or university can bring a group to Cuba under the new OFAC general license (you are therefore ‘licensed’ according to OFAC and the U.S. government), but that does not mean anything in Cuba. To operate legally in Cuba at the People-to-People level, you must also be received and licensed through a Cuba-licensed operator.
The “TSP” (Cuba, and not Cuban, Travel Service Provider) is usually a non-Cuban operation that acts as a travel agent. In the U.S., these Travel Service Providers have a special OFAC license in order to serve as travel agents. These outside-of-Cuba Travel Service Providers link the group with the Cuban Travel Operators like Havanatur.
Many Cuban Tour Operators like Havanatur have the equivalent of “Cuba Travel Service Providers” outside of the the US, too, and these providers–especially if outside the US in Canada, Europe–may not have an OFAC license. And why would they, if they are not U.S.-based? This seems obvious but can be an obstacle for a U.S.-based study abroad company or U.S.-based university.
In addition, what we have seen is that — and this is no way a question of legitimacy — is that the foreign (outside of Cuba) affiliates, even the ones based in the U.S. that have a Cuba Travel Service Provider license to operate as a travel agent for Cuba in the U.S., are not always able to answer license-specific questions in Cuba. In other words, just because a U.S. entity can act as a travel agent for Cuba and is authorized by OFAC to do so, there are licensing requirements on the Cuban end that said travel agency may not be able to answer. The result is a fascinating back and forth between the Cuban licensed entity (the Cuban Tour Operator) and the non-Cuban entity (TSP or travel agent, often outside of the U.S.) that sends them clients. There are now dozens (perhaps more) non-Cuban operations affiliating with Cuban Tour Operators making for some fascinating translations. At the level of programming, out initial observation is that the Cuban Tour Operators vary in flexibility: some need to stick to a rigid itinerary because their license in Cuba was approved as such, others can incorporate constructivist and student-centered learning models with more ease.
Regardless, the administration and implementation of these People-to-People programs behind the scenes is a fascinating point of contact between cultures and educational value systems, and it is in these spaces that, if folks step back from the immediate payment mentality, real intercultural learning takes place. This is a fascinating moment for exchange surrounding full-immersion, educational travel on both ends, foreign and Cuban.