The revised Cuba sanctions created a general license for those providing travel services to authorized U.S. travelers to Cuba. The ink on the Federal Register notice was scarcely dry before room sharing service Airbnb had listings in Cuba up and running.

Of course, the remaining sanctions impose some unusual restrictions on Airbnb’s activities in Cuba. First, U.S. travelers still cannot go to Cuba for fun and mojitos; they must qualify for one of the existing general licenses, e.g., to visit family or do professional research in Cuba. Airbnb needs to get from each of its customers booking a stay in Cuba a certification of the particular section of the OFAC rules which authorizes them to travel to Cuba. These records must be maintained by Airbnb for five years.

Second, Airbnb may only provide these services to U.S. persons because the general license covers travel services for travel authorized by the Cuba sanctions. Those sanctions only authorize travel by U.S. persons, so Airbnb cannot book rooms for Canadians or Italians. (There’s an argument that “authorized” might also mean “not forbidden” which would allow Airbnb to serve non-U.S. customers, but, for the moment, Airbnb is taking the conservative position.)

Third, the new sanctions do not permit Airbnb to provide non-travel related services in connection with these bookings. So, Airbnb cannot help the Cuban “hosts” design their listing or edit their photographs. Even so, many of the listings look like interesting places to stay, even though hot water, Internet, and other ordinary amenities may well be missing. I could, for one, happily stay in the Havana apartment shown in the picture to the right — particularly at its listed price of $56 per night.  And sometimes I think that not having access to the Internet on vacation might actually be a good thing!

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