New guidelines on people-to-people travel

Following complaints by Senator Rubio and others, the Treasury Department changed the rules governing people-to-people travel programs.  I don’t see that the actual regulations have changed; rather, the description of the licensing criteria has been changed in Treasury’s guidelines for applicants (see here [pdf], scroll down on left to “educational activities – people-to-people”).

I am not finding a plain English, side-by-side comparison of the old and the new.  In the absence of that, my reading is that the change consists of adding the following:

·         A clarification of an existing requirement that licensees have an employee or consultant accompanying each group of travelers; i.e. a licensee cannot send a group to Cuba to be led by a Cuban guide or a foreign national.

·         A clarification that the program activities must serve one or more of these objectives: enhancing contact with the Cuban people, supporting civil society, promoting independence from Cuban authorities.

·         A requirement that applicants (or licensees seeking renewal) explain, if their itineraries include meetings “hosted by” high-level government or Party officials, how such meetings serve one or more of the objectives listed above.

Senator Rubio objected to some programs because they appeared frivolous and because they did nothing to promote political change.  Actually, the regulations in this category of travel never included a government requirement that Americans promote political change as a condition of their travel license.  The requirements were, and they remain, that the travel involve full-time educational programs with lots of interaction with Cubans, and the predominant portion of that interaction cannot be with high-level government or Party officials.  What has been added are explicit mentions of optional objectives regarding civil society and independence.

The people-to-people category is the way most Americans not of Cuban descent travel to Cuba.  Cuban Americans travel without restriction, and no one has taken to the floor of Congress to talk of their “abuses” or to impose a requirement that they engage in political activity as a condition of their license to travel to Cuba. 

This would all be a lot easier, and a lot more American I would say, if we simply allowed Americans to travel freely and did not employ executive branch agencies in regulating their activity.  But Cuba policy is a big-government policy, not a limited-government policy.

For his part, Senator Rubio himself does not go to Cuba, for visits or politics or otherwise.

Herald story here.