M E M O R A N D U M
To: Ocean Passages employees, crew, students and affiliates
From: Gregory Belanger, President of Ocean Passages
Re: Compliance with new U.S. policies toward Cuba
Date: November 24, 2017
President Trump recently announced changes to U.S. policy aimed at tightening restrictions on American travel to Cuba. This memo is circulated to everyone associated with Ocean Passages to ensure continued full compliance.
After reviewing the new regulations, we wish to highlight two provisions. First, the new rules prohibit travel to Cuba by self-directed Americans under the “people to people” category. This change does not affect our operations, as all U.S. citizens involved with Ocean Passages travel to Cuba pursuant to specific licensed authorization from the Departments of Treasury and Commerce.
Second, the new regulations prohibit most U.S. individuals and groups traveling to Cuba from patronizing an itemized list of agencies, hotels, restaurants or stores. The rules forbid “direct financial transactions” between covered U.S. citizens with these Cuban entities – defined as originating any transfer of funds that ultimately benefit itemized entities related to the Cuban military, intelligence or security services. Ocean Passages currently undertakes no such direct transactions and will not do so in the future.
We take seriously President Trump’s intent to scrupulously enforce the adjusted rules governing travel to Cuba by Americans. Ocean Passages will continue to adhere to all relevant statutes and regulations, as well as the terms of our U.S. license provisions. We expect everyone associated with our operations to understand and fulfill all of our compliance obligations.
As in the past, all Ocean Passages personnel will be regularly briefed on these responsibilities. Please consult with me personally if there are any questions about compliance.