According to the OFAC existing bookings should be honored. The cruise lines need direction on how to accomplish this....
6. Are authorized travelers who have initiated travel arrangements prior to the addition of an
entity or subentity on the State Department’s Cuba Restricted List required to cancel their
Cuba-related travel plans if their travel arrangements involve direct financial transactions
with a listed entity or subentity?
UPDATED June 4, 2019. Questions are current as of the dates indicated below.
Consistent with the Administration’s interest in avoiding negative impacts on Americans for
arranging lawful travel to Cuba, any travel-related arrangements that include direct financial
transactions with entities and subentities that appear on the State Department’s Cuba Restricted
List will continue to be permitted, provided that those travel arrangements were initiated prior to
the State Department’s addition of the entity or subentity to the list. Once the State Department
adds an entity or subentity to the Cuba Restricted List, new direct financial transactions with the
entity or subentity will not be permitted, unless authorized by OFAC or exempt. For a complete
description of the scope of the prohibition on direct financial transactions and the restrictions and
exceptions that apply, see 31 CFR § 515.209. [11-08-2017]