Travellers under US jurisdiction heading to Cuba are probably more likely nowadays to self certify under the OFAC category “Support for the Cuban People”. By choosing this category your authorisation to travel is under an OFAC general license, so you do not need to “apply” to anyone for anything, but you do need to understand that OFAC’s authorisation places a number of conditions on what you do.
One of those conditions is that " the traveler’s schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule."
This gets a bit tricky because OFAC does not define “full-time”.
Nor does it define “free time” or, separately “recreation” although we probably have a good idea of what is intended.
It’s also particularly tricky for me because I am awake 19 hours a day, which would mean that I would have to develop a full-time schedule of 9.6 hours each day, or I might breach the “free time or recreation” allocation.
Other interesting points to note are:
- Every day is treated the same - you can’t assume if you are there for 7 days then 2 days are a weekend and are “free time” regardless
- If you get off a cruise ship you might not be there long enough to develop a full-time schedule
- You may not be in a physically fit state to achieve a full-time schedule
So now let’s look at what the US could reasonably define as "full-time. An excellent read is here: https://www.thebalance.com/how-many-hours-a-week-is-full-time-employment-2063404
So do we use a 30 hour working week?
Or do we use 35, or 40?
My suspicion is that the US would have to accept 30 hours - it translates to 6 hours a day - if the matter were ever contested. And note that the likelihood of it ever getting to this point is as good as your chance of winning a lottery.
I recommend a more generous approach and that we use 7 hours a day as meeting the “full-time” aspect of the ruling, plus it gives you a near equivalent amount of “free time” to enjoy and get 10 hours sleep - all staying within the crazy rules.
Let’s now begin our “schedule”.
OFAC specify staying at casas as a compliant activity, so we must be able to include the time while we are “active” because it cannot be presumed they offer breakfast.
7am -8am - preparation for breakfast
8am - 9.30am - breakfast at casa and interaction with family
9.30am - 10.30 am - walk to cadeca to exchange money into CUC
10.30 - 12.30 - hire car and guide to enhance contact with the Cuban people
12.30 - 2.pm - lunch at a paladar
(Your 7 hours has been now achieved.)
2.00pm - 4.00pm - siesta
4pm - 10.59pm - free time
So you can see that very little “activity” is needed to quickly fill up your compliant "full-time schedule."
I know Spunky has been gathering many more activities to help you create a schedule for many other fun filled days.