I’ve been in touch with folks at Commerce and Treasury, and yes:
if the people on a boat are going to Cuba under one of the 12 categories approved for a OFAC general license (such as participation in a recognized sporting competition, like the Hemingway tournament), then no BIS license from Commerce is needed and the boat can stay in Cuba for up to 14 days. Also, the Treasury requirement for an OFAC passenger carrier certification license has also been eliminated for such boats.
So, all the boat needs is the CG-3300 permit to enter Cuban territorial waters.
Great progress !
Dr. Jeffery Boutwell serves on the board of The Latin American Working Group in Washington D.C.