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People to People (P2P) Tours and the Cruise Line Spin


#1

Deception and lies underpin the spin from many cruise line offerings to Cuba.

"In order to disembark in Cuba, you will need to purchase a shore excursion through MSC Cruises as part of the People-to-People program" say MSC as you open their website.

So what are the facts?

  • You can disembark with other passengers provided that you certify you meet any one of OFAC’s general licence categories authorising travel to Cuba
  • You do not need to purchase any tour/excursion, irrespective of your chosen OFAC category
  • P2P is a “general license” under OFAC’s §515.565 Educational activities category and has absolutely nothing to do with “tours/excursions”. It’s really for educational exchanges not involving academic study, but cruise lines have re-invented the category to meet their fabricated rules
  • Cruise lines cannot make you change your preferred OFAC category
  • There is no such thing as an “approved tour” for OFAC purposes
  • Choosing P2P instead of “support for the Cuban people” is, technically, one of the most restrictive travel options because it does not allow “free time or recreation”
  • Only P2P requires passengers to retain records sufficient to demonstrate that each individual traveler has engaged in a full-time schedule of activities [CACR §515.565 (b) (6)]

There is a good chance that if you are booking a cruise or boarding it, some cruise line rep or agent will tell you that P2P should be selected because of some fabricated reason that sounds good to them but bears no resemblance to OFAC requirements. Several other threads in this forum cover OFAC in more detail and also debunk many of the claims posted in several cruise line websites.
OFAC certainly requires all travellers to keep a full and accurate record of each financial transaction engaged in for up to 5 years, irrespective of which reason authorised your travel. But unless you chose P2P, OFAC cannot require you to keep or produce an “itinerary” or full time schedule of your activities.


#2

I’m curious: do Canadians have to jump through these same hoops off of a cruise ship?


#3

Most cruises to Cuba will visit via a US port, which places the traveller under US jurisdiction. So if that circumstance fits any nationality, then OFAC compliance applies.


#4

desmei - everyone boarding a cruise in the US is subject to the US rules.

rob - whilst I agree with your criticism of the cruise lines, I would mention that the P2P sub-category has been used for tours for many years - long before the cruise lines were going to Cuba, and was so when such travel was subject to specific licenses, not general licenses. So tht is OFAC viewed them, too.

With regard to the record keeping, it is a good point that the requirements for P2P are more than for other categories, though “Individuals may rely on the entity sponsoring the travel to satisfy his or her recordkeeping requirements with respect to the requirements of paragraphs (b)(1) through (5) of this section.”