NFTC Opposes New OFAC Restrictions on Cuba

Friday, 23 May 2003


The proposed amendments to 31 C.F.R. Part 515 will eliminate many people-to-people educational exchanges to Cuba, eliminating the entire category of licensed travel by U.S. citizens to Cuba for educational activities that do not involve study directly pursuant to undergraduate or graduate degree programs. Limiting travel to Cuba to only those enrolled in a graduate or undergraduate degree course at the accredited U.S. academic institution, the amendments neglect an entire segment of parties interested in traveling to Cuba to strengthen understanding between the two countries.

"We oppose these changes because they eliminate important cultural and educational exchanges between the American and Cuban people," said NFTC President Bill Reinsch. "As a result, direct contact between U.S. and Cuban citizens will be severely limited, further isolating the Cuban people and threatening prospects for democratic reform."

NFTC noted in its letter that some of the United States' most prestigious cultural institutions are currently licensed to conduct 515.565 educational programs in Cuba - all of which stand to be eliminated if the proposed OFAC regulations are adopted - including: the Metropolitan Museum of Art, the Smithsonian Institution, the American Museum of Natural History, the Museum of the City New York, the Houston Museum of Fine Arts, the National Trust for Historic Preservation, the American Folk Museum, Princeton University Art Museum, The Rhode Island School of Design, and the Whitney Museum of American Art.

In addition, the new regulations would deny licenses to companies that specialize in organizing foreign educational travel programs designed to export American values and institutions. These companies include the Ambassador Group, founded in the Eisenhower Administration to promote people-to-people programs abroad.

"The members of these cultural institutions include Americans who are most likely to present a favorable view of our country to Cubans," Reinsch concluded. "The NFTC strongly urges the Administration to reinstate the people-to-people category and allow the free flow of ideas to be exchanged by our most valuable ambassadors of freedom, American citizens."

The National Foreign Trade Council (www.nftc.org) is a leading business organization advocating an open, rules-based global trading system. Founded in 1914 by a broad-based group of American companies, the NFTC now serves 350 member companies through its offices in Washington and New York.

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Mr. David Mills
Chief of Licensing
Office of Foreign Assets Control
U.S. Department of Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

Dear Mr. Mills:

I am writing on behalf of the National Foreign Trade Council, an association of U.S. companies engaged in trade and investment abroad to comment on amendments by OFAC to 31 C.F.R. Part 515, eliminating people-to-people educational exchanges to Cuba. We oppose these changes because they eliminate important cultural and educational exchanges between the American and Cuban people. In fact, they eliminate the entire category of licensed travel by US citizens to Cuba for educational activities that do not involve study directly pursuant to undergraduate or graduate degree programs.

As a result, direct contact between U.S. and Cuban citizens will be severely limited, further isolating the Cuban people and threatening prospects for democratic reform. This undermines the policy course set by President Bush in May, 2002 when he announced the "Initiative for a New Cuba" to encourage freedom in Cuba by influencing the current political structure of Cuba. People-to-people contacts are a key component of that Initiative, accomplishing President Bush's objectives by supporting U.S. foreign policy objectives at no cost to our government. This is because the most effective ambassadors of American values are U.S. citizens interacting with ordinary Cubans.

Programs conducted by some of our country's most prestigious institutions will be eliminated. Organizations licensed to conduct 515.565 educational programs have included, among others: the Metropolitan Museum of Art, the Smithsonian, the American Museum of Natural History, the Museum of the City New York, the Houston Museum of Fine Arts, the National Trust for Historic Preservation, the American Folk Museum, Princeton University Art Museum, The Rhode Island School of Design, and the Whitney Museum of American Art.

In addition, the new regulations would deny licenses to companies that specialize in organizing foreign educational travel programs designed to export American values and institutions. These companies include the Ambassador Group, founded in the Eisenhower Administration to promote people-to-people programs abroad. Among the programs offered by the Ambassador Group alone are criminal justice, care of the aged, comparative education, law, and mental health. Other programs offered by holders of these licenses have included architectural preservation, Cuban music, art and dance, natural history, agricultural organization and production, and rural development.

As in all people-to people programs, these contacts forge bonds of trust and understanding that undercut the effects of isolation and propaganda. Because these organizations are seen as independent from the United States government, their participants can be seen as credible spokespersons for America and American values. In an unobtrusive way, they help to encourage the peaceful transition of Cuba to an open society.

These valuable programs should be continued rather than terminated, as the amendments to 31 C.F.R. Part 515 will do. The members of these cultural institutions include Americans who are most likely to present a favorable view of our country to Cubans. The NFTC strongly urges the Administration to reinstate the people-to-people category and allow the free flow of ideas to be exchanged by our most valuable ambassadors of freedom, American citizens.

Sincerely,

William A. Reinsch
President