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RCC, Azamara, Holland America, Carnival, NCL , MSC - OFAC


RCC link update today. Thanks to CubaJack:


Holland America rules

Updated below, see August 20, 2018
Thanks cubajack.


Carnival procedures and affidavit,
Thanks to RobMe/rederob:
Checklist -https://www.carnival.com/~/media/CCLUS/PDFs/OnlineCheckIn/Cuba_Checklist%20F%20pdf.ashx

Carnival’s affidavit -


Here is the affidavit used by Norwegian Cruise Lines:

Choosing #515.574 Support for the Cuban people is what many will elect if preferring to arrange inexpensive local tours or just walking about.


Here is the MSC info:
2. Re: msc cruise from miami to cuba
Jul. 31, 2018, 4:16 a.m.
MSC advises:

Your affidavit will be included with your e-tickets. Each guest 18 years of age and older is required to print, fill-in, and sign prior to arriving to the port. It is important that each and every guest fills out this form. The form is required per person, not per family. A parent or guardian may complete the form for each guest 17 years of age and younger.

From MSC’s website:

Listed below are the 12 general authorized license categories as defined by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC). Guests who are not participating in MSC Cruises people-to-people educational exchange program plan must participate in at least one of the following activities falling within the general authorized license categories provided by OFAC.

All guests will be required to complete and sign the “Guest Certification for Authorized U.S. travel to Cuba” form prior to boarding the vessel and declaring that their travel falls under one of the below categories or that they are authorized to travel to Cuba under a specific license issued by OFAC (license number and a copy of the license will be required). This Guest Certification form can be found on MSCCubaProgram.com.

Family visits

Official business of the U.S. government, foreign governments, and certain intergovernmental organizations

Journalistic activity

Professional research and professional meetings

Educational activities

Religious activities

Public performances, clinics, workshops, athletic and other competitions, and exhibitions

Support for the Cuban people

Humanitarian projects

Activities of private foundations or research or educational institutes

Exportation, importation, or transmission of information or informational materials

Certain export transactions that may be considered for authorization under existing Department of Commerce regulations and guidelines with respect to Cuba or engaged in by U.S.-owned or -controlled foreign firmsListed below are the 12 general authorized license categories as defined by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC). Guests who are not participating in MSC Cruises people-to-people educational exchange program plan must participate in at least one of the following activities falling within the general authorized license categories provided by OFAC.

Choose “Support for the Cuban People” on the affidavit you will receive with your e-ticket so you can direct your own tours, taxis, and visits to local attractions, restaurants, museums, or wherever you decide.

and, the official website is:



That one seems to have changed. Here is the new link:


Norwegian Cruise Lines currently show 19 travel categories you can choose from.
Some are not general license authorisations, so it begs the question of what happens if you tick the wrong box, like 515.570 Returning Cuban nationals (which nowadays is CACR §515.570 Remittances and has nothing to do with travel authorisations.)


Also, they list Activities in connection with the temporary sojourn of aircraft/vessels as being under section 515.565(b)(2). Isn’t that one a paragraph under educational-people to people?

And, by the way:
Begs the question really doesn’t mean the same as raises the question.


That’s OK, Rob. I didn’t know if you would.
I just wanted to give an example of a logical fallacy in which the reasoner begins with what they are trying to end with.


That would in fact be a logical fallacy if the certification process is not adequate. Do we know for sure that it is not?


Jack, in regard to a full time schedule, I separate a logical fallacy from a sentence which has no meaning.
With regard to your next point about the certification process, I provided an example. OFAC §515.570 allows Remittances, not authorised travel. Moreover, NCL have not only erred on the category of travel, they probably overlooked the transactional prohibitions relating to the transportation of certain Cuban nationals under §515.415 - Travel to Cuba.


I think we are on the same path. There are lots of logical fallacies, and question begging is one of them.
What I meant was that the idea of defining something by reference to itself is a type of faulty reasoning that will result in a meaningless sentence. Kind of like one of the examples of begging the question given in Wikipedia that, I think goes something like "Asia is the largest continent, because it has the most area.
Claim x is that Asia is the largest continent because x is true, where x is Asia has the largest area. Therefore Asia is the largest continent. So we have defined Asia as the largest continent because it is the largest continent. A trivial example, I know.
But, I fear that we are probably boring everybody else, even though we oth are finding this discussion fascinating.


So the point is that while it is true that Asia is the largest, saying it is because it has the most area proves nothing, because those are just two ways of saying exactly the same thing.
That’s why it is circular reasoning.
Not claiming Wikipedia to be anything definitive, it was just an example I liked.
Here’s another one:


I liked Jack’s cartoon because in circular reasoning there is nothing proving either the premise or conclusion.
Hiring charlatans can equally cause a business to be successful.
Or, a business might have the right employees, but be unsuccessful because it does not have enough of them.

Cruise lines successfully “sell” excursions to Cuba-bound passengers because Trump removed OFAC’s “individual people-to-people” travel authorisation. They usually omit OFAC’s travel authorisation for individuals to go under “support for the Cuban people.”

On the other hand, OFAC recently fined a Bank over $53m, demonstrating it has the right people to generate solid revenues. But OFAC does not devote much (if any) of its resources to checking the compliance of individual travellers. So take the advice of cruise line representatives with a grain of salt and choose the OFAC category which you prefer, rather than be misled.


Also, Rob, as I think you pointed out somewhere else, it is probably pretty easy to comply with the “support for the Cuban people” category. As long as you try to patronize independent businesses, and keep a record of the compliant transactions, it should be easy.
So, for the people who want to comply, they can, and for the ones who don’t really care, the chance of an individual traveler being prosecuted is very remote.


And here is the latest form from Carnival, thanks to Bob R on that other forum:


Interesting that Carnival are the first to be sued under Helm Burton.

(Why just them and not the other cruise lines ?)


Maybe because they are already in trouble with the US Government over repeated pollution charges and can hope for no breaks in front of a judge.
From Wikipedia:
Since 2017, Carnival Corporation has been on probation, after having been found to “illegally dumping oil into the ocean from its Princess Cruises ships and lying about the scheme.” Carnival Corporation also had to pay a $40 million fine.[23]

In April 2019, Carnival Corporation was accused of violating probation rules. The allegations include 800 incidents from April 2017 to April 2018. A federal judge has threatened to impose severe fines which may increase tenfold . The judge also stated that Carnival ships may be temporarily banned from docking in US ports. The final verdict will be announced in July 2019 at the hearing.[24]


I doubt that.

Another thing - I see that that the lawyer for Carnival was with the Cuba-America National Foundation and says that he was involved in drafting the Helms-Burton law.


In the US, litigants who delay, obfuscate and appeal in hopes of settlement are well known. Carnival is such a player. Justice isn’t blind in the land of the free. IMO